Question ID
2022_6376
Legal act
Regulation (EU) No 575/2013 (CRR)
Topic
Credit risk
Article
4, 181
Paragraph
1, 1
Subparagraph
55, (a)
COM Delegated or Implementing Acts/RTS/ITS/GLs/Recommendations
Not applicable
Article/Paragraph
na
Type of submitter
Credit institution
Subject matter
Calculation of loss given default for fully off-balance exposures in case there are no additional drawings after the default date.
Question

According to point 55 of Article 4(1) of Regulations (EU) No 575/2013 (CRR) ‘Loss given default’ or ‘LGD’ means the ratio of the loss on an exposure due to the default of a counterparty to the amount outstanding at default.

 

In case the exposure is fully-off balance at the moment of default and there are no additional drawings after default, both the numerator and the denominator of the LGD will be equal to zero. This means that the LGD cannot be calculate using the definition stated above. Should the realized LGD be set equal to zero in this case? 

Background on the question

Article 181(1)(a) of Regulations (EU) No 575/2013 (CRR) specifies that LGDs shall be estimated on the basis of the average realized LGD by facility grade or pool using all observed defaults.

 

In case a facility is fully off-balance at the moment of default and there are no additional drawings after default, the LGD can not be calculated following the definition in point 55 of Article 4(1). Because both the numerator and denominator are equal to zero. However, Article 181(1)(a) of Regulations (EU) No 575/2013 (CRR) requires to calculate LGD for all observed defaults.

 

For the purpose of Article 181(1)(a) and calculating the realized LGD for exposures fully off-balance at the moment of default (i.e., no on-balance exposure) and with no additional drawings, the following options can be considered:

  1. Set the LGD equal to zero, or
  2. Exclude these exposures from LGD estimation and calibration.

 

The situation where there is no on-balance exposure at the moment of default and no post default drawings is illustrated by two example below:

 

Example 1

A simple example is a revolving exposure, which happens to be fully off-balance at the moment of default and there are no post default drawings.

 

Example 2

Suppose a bank guarantee is provided by the institution to the obligor without any other products. In other words, the bank guarantee is the sole exposure the institution has towards the obligor. Suppose further that the obligor defaults and the guarantee is not claimed by the beneficiary after default (i.e., no additional drawings after default).

Submission date
Rejected publishing date
Rationale for rejection

This question has been rejected because the issue it raises is not material i.e. it does not raise a prudential, payments, consumer protection, resolution or other regulatory issue that is within the EBA’s remit.

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Status
Rejected question