Response to consultation on Regulatory Technical Standards on the allocation of off-balance sheet items and UCC considerations
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Question 1. Do you have any comment on the non-exhaustive list of examples provided?
No
Question 2. Which is the average period of time given to the client to accept the mortgage loan offer?
6 months
Question 3. What is the applicable percentage tht institution currently apply to these commit-ments?
20% or 50% depending on whether the original maturity is below or above 1 year
Question 4. What is the average acceptance rate by the client of a mortgage loan offered by the bank?
?
Question 5. Do you have any comment on the allocation criteria proposed under Article 1?
No
Question 6. Do you have any suggestion regarding allocation criteria for buckets 4 and 5?
No
Question 7. Do you have any comment on the factors that may constrain unconditionally cancel-lable commitments proposed under Article 2?
No
Question 8. Do you have any comment on the notification process proposed under Article 3?
No
What is the materiality in your institution of the off-balance sheet items that would fall under the categories “Other off-balance sheet items carrying similar risk and as commu-nicated to EBA” listed in each bucket of Annex I?
?
Do you identify any specific item you may hold off-balance sheet that is currently classi-fied as “Other off-balance sheet items carrying similar risk and as communicated to EBA” and that may experience a change in bucket allocation based on the criteria listed in Ar-ticle 1 of these RTS? What would be the related change in the associated percentage as per article 111(2)?
It is not clear how non-credit risk related off balancesheet items should be treated. One such example is mentioned in CRR article 400 (2) (j). These guarantees have no credit risk attached to them and the risk they cover is purely of an operational character. It should be clear from these RTS that guarantees etc. which are not credit risk related should not be treated according to Annex 1.