- Question ID
-
2025_7382
- Legal act
- Regulation (EU) No 575/2013 (CRR)
- Topic
- Credit risk
- Article
-
223
- Paragraph
-
4
- Subparagraph
-
(b)
- COM Delegated or Implementing Acts/RTS/ITS/GLs/Recommendations
- Not applicable
- Article/Paragraph
-
N/A
- Name of institution / submitter
-
Kurt Lund Accounting
- Country of incorporation / residence
-
Sweden
- Type of submitter
-
Accounting firm
- Subject matter
-
AIRB combined with Financial Collateral Comprehensive Method
- Question
-
Article 223 para 4 subpara (b) indicates that banks using the A-IRB approach can also utilize the Financial Collateral Comprehensive Method (FCCM). Does the EBA agree with this?
- Background on the question
-
According to CRR article 108 institutions using the AIRB approach may take into account the effect of funded credit protection according to chapter 3 whereas institutions using the FIRB approach may take into account the effect of funded credit protection according to chapter 4. Given that the FCCM method is placed within chapter 4 it was always our assumption that the FCCM method could only be utilized by institutions using the Foundation approach (and the standardized approach) and not by institutions using the AIRB approach with own estimates of LGD and CCF. However the CRR3 revised text in article 223 para 4 (b) mentions that institutions using IRB-CCF must set these to 100% instead of using own estimates of CCF according to article 166 (8), (8a) and (8b) if and when they are using the FCCM method. Given that IRB-CCF is exclusively an approach that can be used by institutions using the AIRB approach it must therefore be deduced that institutions using AIRB with own estimates of LGD and CCF can also utilize the FCCM method despite the fact that it is mentioned in chapter 4 and not in chapter 3.
- Submission date
- Status
-
Question under review
- Answer prepared by
-
Answer prepared by the EBA.