Would the EBA advise whether there is any limitation on the offset of AVAs against EL?
CRR Article 159 states that ‘Institutions shall subtract the expected loss amounts…from the general and specific credit risk adjustments and additional value adjustments(AVAs) in accordance with Articles 34 and 110’. In accordance with Recital (65) and Article 34 an institution must deduct the AVAs resulting from the application of the requirements of Article 105 (requirements for prudent valuation) to all assets measured at fair value where this results in a lower carrying value than that recognised for accounting. The Credit and Counterparty Risk capital requirements, including the EL amount, are calculated using the higher accounting values, not the AVA adjusted values. As a result, without an adjustment to the capital requirements on those assets, there is double hit to capital. The offset against EL in Article 159 is a means of mitigating that double hit. There are no other mechanisms with the CRR to offset PVAs.
The intention behind Article 159 of Regulation (EU) No. 575/2013 (CRR) is to ensure that expected loss amounts calculated under the IRB approach are only deducted from own funds to the extent they have not already been reflected through either:
- general and specific credit risk provisions within in the financial statements, which are the starting point of the own funds calculation; or
- adjustments to these general and specific credit risk provisions, deducted from own funds according to Article 34 to meet prudent valuation requirements of Article 105 of the CRR.
It is therefore only Additional Value Adjustments deducted from own funds according to Article 34 of the CRR that should be included in this calculation.
Update 26.03.2021: This Q&A has been reviewed in the light of the changes introduced to Regulation (EU) No 575/2013 (CRR) and continues to be relevant.