2015_1757 Definition for short-term letters of credit

Question ID:: 2015_1757
Legal Act:: Regulation (EU) No 575/2013 (CRR)
Topic:: Other issues
Article:: 4, 120
Paragraph:: 1(80)
COM Delegated or Implementing Acts/RTS/ITS/GLs/Recommendations:: Not applicable
Article/Paragraph:: n.a.
Disclose name of institution / entity:: No
Type of submitter:: Other
Subject Matter:: Definition for short-term letters of credit
Question:: What does short-term in this context mean? 90 days or 1 year? Residual maturity or original effective maturity?
Background on the question:: In different parts of CRR the term 'short-term' is used but with different meaning. For example: '... fixed short-term maturity, generally of less than one year', Article 4 (1)(80) CRR; 'Exposures to an institution of up to three months residual maturity ', Article 120 CRR; 'For exposures to unrated institutions with an original effective maturity of three months or less', Article 121 CRR.
Date of submission:: 26/01/2015
Published as Final Q&A:: 19/06/2015
Final Answer:: Article 4(1)(80) of Regulation (EU) No 575/2013 (CRR) defines 'trade finance' as 'financing, including guarantees, connected to the exchange of goods and services through financial products of fixed short-term maturity, generally of less than one year, without automatic rollover'. Therefore, to the extent that letters of credit are typically trade finance products, 'short term' should be understood as implying generally a maturity of less than one year at origination.
Status:: Final Q&A
Answer prepared by:: Answer prepared by the EBA.
Note to Q&A:: 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.