We are reaching out concerning the instructions published in CRR3 REGULATION (EU) 2024(1623).

Specifically, we would kindly request clarification about the type of exposures that should be considered in COREP Template C10.00 row 0152.

In fact, Article 465(5) states that: “(b) until 31 December 2029, a risk weight of 45 % to any remaining part of the exposures secured by mortgages on residential property up to 80 % of the property value determined in accordance with Article 125(1), first subparagraph, provided that the adjustment to own funds requirements for credit risk referred to in Article 501 is not applied.”

And Article 125, to which it refers, indicates that the share up to 55% must be treated as secured, on the other hand the share above 55% is considered as unsecured: “For an exposure secured by residential property as referred to in Article 124(2), point (a)(i) or (ii), the part of the exposure up to 55 % of the property value shall be assigned a risk weight of 20 %... The remaining part of the exposure referred to in the first subparagraph, if any, shall be risk weighted as an exposure to the counterparty that is not secured by residential property.” 

We therefore understand that the exposures to be considered in the scope of the row 0152 on C10.00 Template (55% to 80%) are unsecured exposures.

Thank you in advance for your kind clarification and guidance.