Regulation (EU) No 575/2013, as amended by CRR 3, introduced changes to Articles 236 and 236a within the CRM framework. These amendments explicitly recognise that:

• Exposures treated under the slotting approach may benefit from unfunded credit protection; and

• Such exposures may also be recognised as providers of unfunded credit protection when they are used to cover other IRB exposures.

However, these regulatory changes do not appear to be reflected in the current COREP template C 08.01. Specifically, for row 0080 (specialised lending exposures), columns 0040 and 0070, as well as column 0080, are greyed-out. As a result, institutions are not able to report CRM techniques for exposures subject to the slotting approach.

Previous Q&As (EBA Q&A 2014_1604 and 2017_3295) have addressed this issue; however, those clarifications pre-date the CRR 3 amendments. In light of the updated Articles 236 and 236a, it is respectfully requested that the COREP reporting framework be updated accordingly to enable the appropriate reflection of CRM techniques for slotting exposures.