• The issue at stake is about a committed credit facility provided to multiple borrowers, with all borrowers referred to in such facility belonging to the same overarching corporate group which, from group perspective, would qualify as a non-financial corporate.
• Each of the individual borrowers might draw the full (undrawn) amount of the facility. While the group as such relates to a non-financial corporate, among the various borrowers, it is understood (also from the clarification provided in the recent email) that multiple entities meet the definition of a financial customer under Article 411(1) CRR on a stand-alone basis.
• The question is about the LCR treatment of this committed credit facility, namely if the credit institution would need to apply to this facility the outflow rate assumption for a financial customer (on the basis of Article 31(8)(c) LCR DR) or a non-financial (corporate) customer (on the basis of Article 31(4) LCR DR).

Applicable rules do not include explicit guidance on the LCR treatment of committed credit facilities where there are multiple borrowers. In general, the outflow rates in the LCR are assumed to reflect the likelihood of various categories or types of liabilities and off-balance-sheet commitments of being run off or being drawn down during a period of idiosyncratic and market-wide stress. The outflow rates conceptually differ between funding providers, also depending on their level of sophistication with financial customers assumed to have quicker and more profound information on the liquidity and funding situation of credit institutions.