Could you please confirm that subordinated loans according to Art 62.a CRR, which are acknowledged as Tier 2 are not regarded as equity exposures according to Art. 133.3 CRR.
The term " regulatory capital instruments" used in Article 133.3 CRR is not defined in the CRR. Therefore it is questionable whether items like subordinated loans acc. to Article 62.a CRR have to be treated as regulatory capital instruments and therefore be qualified as equity exposures in the sense of Art. 133.3 or only capital instruments that are securitized and emitted as securities.
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