According to Article 428j(1) of Regulation (EU) No 575/2013 (CRR), institutions shall take into account the residual contractual maturity of their liabilities and own funds to determine the available stable funding factors to be applied under Section 2.

However, Article 428j(2) CRR provides that for options exercisable at the discretion of the institution, the institution and the competent authorities shall take into account reputational factors that may limit an institution's ability not to exercise the option, in particular market expectations that institutions should redeem certain liabilities before their maturity.

Commercial paper is a type of short-term debt securities that can be issued on a standalone basis or issued as part of a commercial paper programme. When issued under a commercial paper, it may involve an issuer continuously rolling over its commercial paper under a pre-defined limits agreed between the issuer and the underwriter.   

Under the scenario that a commercial paper programme involves an agreement between the issuer and the underwriter where the underwriter gives an irrevocable firm commitment to ensure the rollover of the commercial paper until the residual maturity of the programme (within the agreed programme size), it is unclear whether this can in any way be considered as an option exercisable at the discretion of the institution in accordance with Article 428(j)(2) CRR.