Single Rulebook Q&A

Question ID: 2017_3366
Legal act : Regulation (EU) No 575/2013 (CRR) as amended
Topic : Credit risk
Article: 111
Paragraph: 1
Subparagraph: c
Article/Paragraph : N/A
COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
Type of submitter: Consultancy firm
Subject matter : Original maturity for off balance sheet items
Question:

How is the "original maturity" identified for items in CRR Annex 1 (2)(b)(ii)?

Background on the question:

As per Article 111 CRR, to identify the risk category to assign for the credit risk adjustment is based on criteria set out in Annex 1. Within Annex 1, item 2 (medium risk) bullet (b, ii) "undrawn credit facilities (agreements to lend, purchase securities, provide guarantees or acceptance facilities) with an original maturity of more than one year;"
For example, if a firm offers a 10 year loan which has been approved, but not yet drawn down, and has 90 days until the offer expires, would the original maturity for the treatment of off balance sheet items be 10 years or 90 days?
To identify whether to treat undrawn 10 year loans that have a 90 day expiry term should be treated with an original maturity of less than 1 year or more than 1 year.

Date of submission: 23/06/2017
Published as Final Q&A: 08/06/2018
EBA answer:

For the purposes of paragraphs (2)(b)(ii) and (3)(b)(i) of Annex I of Regulation (EU) No 575/2013 (CRR) the relevant original maturity is the period that starts when the credit facility has been granted and during which the undrawn credit facility could be drawn and become a drawn credit facility. The classification of the items remains unchanged until the expiration of the offer or the date when the off-balance sheet item becomes a drawn credit facility.

In the example of a 90 day offering period for a 10 year loan, the facility can be drawn only during a period of 90 days, which is not more than one year, thus the off-balance sheet item is to be classified as medium/low risk according to paragraph (3)(b)(i) of Annex I CRR.

However this application of the term “original maturity” does not constrain the maturities relevant for other purposes, such as for determining risk weights (e.g. for the risk weight according to Article 121(3) CRR for exposures to unrated institutions with an original effective maturity of three months or less) or for the recognition of credit risk mitigation (for which Article 238(1) CRR determines the effective maturity of the underlying as the longest possible remaining time before the obligor is scheduled to fulfil its obligations, subject to a maximum of five years).

Status: Final Q&A
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