Appropriate CR SA sub-exposure class categorisation (line items reported within C02.00, C07.00 and C09.01, where applicable) of the portion of an exposure “secured by mortgages on immovable property” which is also secured by cash or subject to other form of credit protection such as eligible guarantees.

Some of the exposures “secured by mortgages on immovable property” existing on an institution’s loan book are also secured by other forms of credit protection, such as cash or eligible guarantees. For such exposures, it is not clear as to which sub-exposure class such portion of the exposure (e.g. the cash-secured portion) shall be attributed.    For example, assume that an institution has a non-IPRE exposure (loan to natural person) secured by residential immovable property, which is also partially secured by cash. To which of the following sub-exposure classes will the portion of the exposure that is secured by cash collateral be classified?   (i)    Secured by mortgages on residential immovable property - non-IPRE (secured) - C09.01, r0091; C02.00, r0151 (ii)   Secured by mortgages on residential immovable property - non-IPRE (unsecured) - C09.01, r0092; C02.00, r0152 (iii)  Secured by mortgages on residential immovable property - Other - non-IPRE - C09.01, r0093; C02.00, r0153   NB: Please also affirm that in the referenced example (i.e. retail counterparty), the Original exposure pre-conversion factors related to such cash-secured portion shall be equivalent to a risk weight of 75% in line with Art 124(1)(a), which is subsequently reduced to 0% through the reporting of CRM techniques with substitution effect via the “Other Items” exposure class (under the financial collateral simple method), in line with the principle applied in EBA Q&A 2016_2693 .    In the quoted example, we understand that such portion shall be reported as “Secured by mortgages on residential immovable property - Other - non-IPRE”.

Section 3.2.4.4 of Annex II, Part II – Credit Risk SA , provides details of the sub-exposure classes related to the exposure class “secured by mortgages on immovable property and ADC exposures”, as referred to in Article 112(i). The sub-exposure classes related to the non-ADC category are reported in designated line items within COREP C02.00 (r0150 to r0159 and r0900), C09.01 (r0090 to r0094 and r0900 to r0905) and relative exposure classes within C07.00.