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  1. Home
  2. Single Rulebook Q&A
  3. 2026_7809 Application of the current market value as a cap for immovable property collateral
Question ID
2026_7809
Legal act
Regulation (EU) No 575/2013 (CRR)
Topic
Credit risk
Article
229
Paragraph
1
COM Delegated or Implementing Acts/RTS/ITS/GLs/Recommendations
Not applicable
Article/Paragraph
n.a.
Type of submitter
Other
Subject matter
Application of the current market value as a cap for immovable property collateral
Question

Should the most recent market value constitute the maximum permissible (“cap”) for prudential purposes, even when the revaluation mechanisms under Article 229 would otherwise yield a higher value?

Background on the question

Under the CRR3 framework, Article 229(1)(d) establishes that the value applied by institutions may not exceed the property’s current market value. At the same time, Article 229 introduces a more structured approach to determining the property value, requiring institutions to compute an average based on a series of equidistant valuation points over a defined historical period. 

In practice, these two requirements may conflict in situations where the most recent market valuation is lower than both the origination value and the average value derived from the Article 229 methodology. Such cases raise an important question:  should the prudential cap in Article 229(1)(d) override the averaged value, thereby limiting the property value to the latest market valuation, even when the historical averaging process would otherwise produce a higher figure?

Submission date
02/04/2026
Rejected publishing date
15/09/2026
Rationale for rejection

This question has been rejected because the issue it deals with is already addressed in Article 229(1) CRR, which requires the valuation of immovable property to meet all the requirements set out therein. The regulatory framework is therefore considered sufficiently clear and unambiguous in this respect.

Status
Rejected question

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