Our primary business is Factoring. Therefore our balance credit figures are mainly invoices / accounts receivables, which we have bought from our clients. As security / protection against credit losses we have established a credit insurance with a credit insurance company. Can we use the credit insurance ("Warenkreditversicherung") as CRM technique? Is column 290 "other commitments" in template LE2 the correct position to fill in the credit amount covered by our credit insurance contract? To our understanding "credit insurance" could be regarded as a position under item (1) k) or (2) b) iv) of CRR-Appendix I .
In general, it is not possible to say whether credit insurance can be used as CRM technique; this depends on the circumstances of the individual case.
A credit insurance might qualify as guarantee. The eligibility criteria for the recognition as guarantee can be found in Articles 399 and 403 of Regulation (EU) No. 575/2013 (CRR) in connection with the referenced requirements laid down in Part Three, Title II, Chapter 4 of CRR. The requirements set out in Article 201 CRR (eligibility of protection provider), Article 213 CRR (general requirements for unfunded credit protection) and Article 215 CRR (additional requirements for guarantees) are of particular importance.
Under the assumption that all eligibility criteria are fulfilled the amount covered by the protection provider shall be included either in column 280, or in column 290 of template C 28.00 (LE 2) of Regulation (EU) No 680/2014 13 ITS on Supervisory Reporting of institutions (ITS) depending on concrete properties of the guarantee.