- Question ID
 - 
            2014_841
 - Legal act
 - Regulation (EU) No 575/2013 (CRR)
 - Topic
 - Market risk
 - Article
 - 
            274
 - Paragraph
 - 
            3
 - COM Delegated or Implementing Acts/RTS/ITS/GLs/Recommendations
 - Not applicable
 - Article/Paragraph
 - 
            0
 - Type of submitter
 - 
            Credit institution
 - Subject matter
 - 
            Regulatory Add-on % for Inflations Swaps
 - Question
 - 
            
Should point 3 of Annex II (types of derivatives) have a title? Points 1 and 2 both have titles; it is inconsistent that point 3 has no title. Article 274 (3) makes reference to "contracts relating to commodities other than gold, referred to in point 3 of Annex II". What derivative types, as classified in table 1 in the article, does point 3 cover? This ambiguity leads me to ask should an Inflation swaps linked to RPI index, be treated as an 'Interest rate' contract or a 'Commodity' Contract? Given the current wording of point 3, Annex II suggests that Inflation swaps should be treated as Interest Rate contracts, they are of a similar nature to interest rate contracts.
 - Background on the question
 - 
            
Fully explained in text of question.
 - Submission date
 - Final answer
 - 
            
An inflation swap linked to Retail Prices Index (RPI) is a swap which involves an exchange of interest calculated by reference to the RPI and another reference rate.
This transaction can be considered an interest-rate contract because it involves the real interest rate (i.e. the interest rate net of inflation).
Accordingly, an inflation swap has to be treated as an interest-rate contract for the determination of PFE with the Mark-to-Market method according to Article 274(2) of Regulation (EU) No. 575/2013.
 - Status
 - 
            Archive
 - Answer prepared by
 - 
            Answer prepared by the EBA.
 - Note to Q&A
 - 
            
Update 16.09.2021: This Q&A has been archived in light of the change(s) in Article 274 to Regulation (EU) No 575/2013 (CRR), applicable from 28.06.2021.