Please clarify the requirement in Point 38 of Annex II, part II: where a credit assessment is not
available under both (a) and (b), i.e. there is not both a credit assessment assigned to the PRIIP and

Question

Please clarify the requirement in Point 38 of Annex II, part II: where a credit assessment is not
available under both (a) and (b), i.e. there is not both a credit assessment assigned to the PRIIP and
a credit assessment assigned to a relevant obligor, but one is available solely under (a) or solely under
(b), is it possible to use either of these (depending on which of the two is available)?

ESA Joint Committee (EBA, ESMA, EIOPA) · Accepted Answer

A default credit assessment as set out in Point 43 of Annex II is to be applied in the absence of a credit
assessment assigned to the PRIIP, the relevant obligor, or both. The measures under Points 46 to 49
may also apply. In general, where a credit assessment has been assigned at the level of the PRIIP this

should take precedence as to a credit assessment at the level of relevant obligors in relation to the
PRIIP. Where there are multiple obligors for which a credit assessment is necessary, and a credit
assessment is not available for certain of these, the default credit assessment according to Point 43
shall be applied for each of these obligors for which a credit assessment is not available.

Please clarify the requirement in Point 38 of Annex II, part II: where a credit assessment is not available under both (a) and (b), i.e. there is not both a credit assessment assigned to the PRIIP and

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