Question ID
2025_7401
Legal act
Regulation (EU) No 575/2013 (CRR)
Topic
Credit risk
Article
124
Paragraph
1
Subparagraph
(a) and (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
Interaction between CRR3 article 124 and article 193
Question

When should an IPRE exposure be riskweighted at 150% according to CRR3 article 124 para 1 (b)?

Background on the question

We are seeking clarification on the interaction between article 124 para 1 (a) and (b) and article 193 para 1. According to CRR3 para 4 (75b) an IPRE exposure must be secured on real estate (either RRE or CRE). Further according to article 124 1 (b) an IPRE exposure shall be assigned a riskweight of 150% and according to CRR3 article 124 para 1 (a) a non-IPRE exposure must be risk weighted as an exposure without collateral (typically risk weight of 100%). Article 124 para 1 (b) therefore seems to be in violation with CRR3 article 193 para 1 where it says the following: "No exposure in respect of which an institution obtains credit risk mitigation shall produce a higher risk-weighted exposure amount or expected loss amount than an otherwise identical exposure in respect of which an institution has no credit risk mitigation".

Submission date
Rejected publishing date
Rationale for rejection

This question has been rejected because it is considered that EBA guidance or clarification is not needed with regard to the issue that it raises. For example, this can be the case where it is considered that the existing regulatory framework is sufficiently clear and unambiguous, or where different practices may be possible but it is not currently necessary to harmonise these further through the Q&A process.

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.

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Status
Rejected question