1) Can the part of the off-balance exposure that is covered by the (to be vested) mortgage inscription be taken into account as 'fully secured and completely secured by mortgage' under Article 125(1) CRR? 

2) Can the part of the off-balance exposure that is covered by the (to be vested) mortgage guarantee be taken into account as credit risk mitigation under Article 203 CRR?

A credit institution has loan commitments for the provision of mortgage loans. The loan commitments relate to mortgage loan offers granted by the institution to clients, and can be either already accepted by the client, or pending acceptance (or refusal) by the client.

The loan offer is contractually cancelled if the loan offer conditions are not fulfilled, among which are the vesting of a mortgage inscription on the property, or the vesting of a (unfunded) mortgage guarantee (national guarantee scheme provided by a government-backed foundation). 

The official (opposable to third parties) mortgage act and vesting of the mortgage inscription and/or mortgage guarantee is done with the passing of the mortgage act by the notary. 

Since the effective payment of credit (the moment the off-balance sheet commitment is payed and goes to an on balance exposure) is conditional on the vesting of the mortgage inscription and/or mortgage guarantee, it is unclear whether this can already be taken into account as credit risk mitigation.

This question has been rejected because the matter it refers to is addressed in Article 208(20 and Article 197 CRR and it has been clarified in Q&A 3332 and Q&A 4986.