In case of applying article 89 CRR in combination with article 90 CRR for a risk exposure (asset) is there a requirement of calculating an additional valuation adjustument (AVA) although the calculated amount of CET1-deduction of the risk exposure already lowers CET1?

The Commission Delegated Regulation (EU) 2016/101 states that there is a need to calculate additional valuation adjustments where the application of prudent valuation would lead to a lower absolute carrying value for assets than recognised in accounting.

The question is whether the calculation of AVA is also neccesary in the case where a risk position is reduced by CET1-deduction (application of article 89 in combination with articel 90 CRR).

The following example shall illustrate the issue:

Fair Value = 100 Mio. EUR (FV)
Prudent Value (calculated on 100 Mio. EUR) = 87,5 Mio. EUR (PVA[A]) => AVA[A] = 12,5 Mio. EUR

CET1-deduction (art. 89/90 CRR) = 20 Mio. EUR (A) => new "Fair Value" / CoRep Exposure Value = 80 Mio. EUR

Prudent Value (calculated on 80 Mio. EUR) = 69,5 Mio. EUR (PVA[A]) => AVA[B] = 10,5 Mio. EUR

Following the fundamental principles of the PruVal guidelines, in our view a prudent value has already been determined for the asset by CET1-deduction (A = 20 Mio. EUR), because the amount of CET1-deduction clearly exceeds the amount of AVA, either calculated on the original book value of 100 Mio. EUR (AVA[A] = 12,5 Mio. EUR) or on the reduced book value of 80 Mio. EUR (AVA[B] = 10,5 Mio. EUR).

It has to be clarified, if and under which constellation an AVA has to be calculated for a risk position where articles 89 and 90 CRR are apllied und lead to a significant CET1-deduction.

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