Question ID:
Legal Act:
Regulation (EU) No 575/2013 (CRR)
Credit risk
COM Delegated or Implementing Acts/RTS/ITS/GLs/Recommendations:
EBA/GL/2019/01 - Guidelines on specification of types of exposures to be associated with high risk under Article 128(3) of CRR
CCF and ECL provisioning
Disclose name of institution / entity:
Type of submitter:
Subject Matter:
Article 111 or about

What CCF and provisions should be allocated, if any, in year 1/2/3/4 considering this special situation that I cannot find in the regulation?

Background on the question:

We wanted to understand under the standardised approach the capital requirements for liquidity guarantees. 

From an insurance point of view, what capital requirements (and CCF)  will attract a facility whereas is guaranteed the liquidity on a project finance loan between the 5th and 10th year (the first 5 years no risk)? The overall project though is 10 years, but the guarantee is provided just for the last 5 years (therefore, in the first 5 years the guarantee will not be called and the same if the project default before the 5th year the insurance is not liable. Otherwise between the 5th and 10th year is a committed guarantee).

The product in the cause is an insurance product (off-balance sheet item). 

Date of submission:
Published as Rejected Q&A
Rationale for rejection:

This question has been rejected because the issue it raises is beyond the remit of the Q&A process and as such it cannot be addressed via a Q&A. 

The Single Rule Book Q&A tool has been established to provide explanations and non-binding interpretations on questions relating to the practical application or implementation of the provisions of legislative acts referred to in Article 1(2) of the EBA’s founding Regulation, as well as associated delegated and implementing acts, and guidelines and recommendations, adopted under these legislative acts. The Q&A process cannot, for example, consider issues which would require changes to the regulatory framework.

For further information on the purpose of this tool and on how to submit questions, please see “Additional background and guidance for asking questions”.

Rejected question