EBA · 2025_7503 Question under review

fully and completely secured by mortgages for the purpose of the deduction of non performing exposures

Regulation
Regulation (EU) No 575/2013 (CRR)
Article
47c, para. 1
Topic
Credit risk
Submitted by
Credit institution
Submitted
2025-06-20
Answer provided by
ESAs (EBA, ESMA, EIOPA)

Question

In the context of the CRR3 and the application of the deduction of non-performing exposure from Common Equity Tier 1 as per article 47c, we would like to clarify the requirements of “ fully and completely secured by mortgages” in order to determine the "secured part of a non-performing exposure".

Background

The subparagraph refers to Title II of Part Three, which involves article 124, 125 and 126 for exposures secured by mortgages on immovable property. These articles introduce methods where risk weights are applied to a portion of the exposure (up to 55% or up to the entire amount of the and in both case up to the nominal amount of the lien). These articles don’t define the requirement of “fully and completely secured by mortgages”. By “ fully and completely secured by mortgages”, should we consider as the "secured part" only the entire exposure up to the nominal amount of the lien or the property value whichever is lower.
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Original source: European Banking Authority, Q&A ID 2025_7503

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