- Question ID
- 
            2018_4293
- Legal act
- Directive 2013/36/EU (CRD)
- Topic
- Supervisory reporting - Supervisory Benchmarking
- Article
- 
            78
- Paragraph
- 
            2
- COM Delegated or Implementing Acts/RTS/ITS/GLs/Recommendations
- Draft ITS on Supervisory Reporting of Institutions (for benchmarking the internal approaches)
- Article/Paragraph
- 
            Annex IV, C103, c210-c220
- Name of institution / submitter
- 
            BaFin
- Country of incorporation / residence
- 
            Germany
- Type of submitter
- 
            Competent authority
- Subject matter
- 
            Definition of numerator for loss rate
- Question
- 
            How should the numerator of the loss rate be computed when some credit adjustments are applied to the exposure before the default date. 
- Background on the question
- 
            Ensure that there is no other interpretation. 
- Submission date
- Final answer
- 
            In order to ensure a meaningful benchmarking analysis where the loss rate is compared with the LGD, it is necessary that the numerator of the loss rate incorporates all the credit risk adjustments and write-offs related to the exposures that defaulted within the year preceding the reference, including the credit risk adjustments applied before the default date. 
- Status
- 
            Archive
- Answer prepared by
- 
            Answer prepared by the EBA.
- Note to Q&A
- 
            Update 26.03.2021: This Q&A has been archived in the light of the most recent amendments to the ITS 2016/2070 on Supervisory Benchmarking.