EBA · 2025_7583 Rejected question

Clarification on the term “fully and completely secured by mortgages” in Article 47c(1) in the context of Non-Performing Exposures (NPEs).

Regulation
Regulation (EU) No 575/2013 (CRR)
Article
47c, para. 1
Topic
Supervisory reporting - COREP (incl. IP Losses)
Submitted by
Credit institution
Submitted
2025-09-17
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Question

Within the context of Article 47c(1), how should the “secured” part of a non-performing exposure be interpreted, given that the term “fully and completely secured by mortgages” is no longer defined in Title II of Part Three?

Background

Article 47c(1) states that “the secured part of a non-performing exposure is that part of the exposure which, for the purpose of calculating own funds requirements pursuant to Title II of Part Three, is considered to be covered by a funded credit protection or unfunded credit protection or fully and completely secured by mortgages .”  Under CRR II, an exposure was considered as “fully and completely secured by mortgages” , if it met the conditions laid down in points (a) to (d) of Article 125(2), or points (a) to (d) of Article 126(2), in relation to exposures secured by mortgages on residential and commercial immovable property, respectively.  However, CRR III no longer specifies these conditions within Title II of Part Three. Clarity is therefore being sought on what should be considered as the “secured” part of a non-performing exposure, given that the term “ fully and completely secured by mortgages ” is still included in Article 47c(1).
No answer published yet.

Original source: European Banking Authority, Q&A ID 2025_7583

This Q&A is published by European Banking Authority and is non-binding. It does not constitute legal advice. Updated weekly from official ESA sources.

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