- Question ID
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2017_3426
- Legal act
- Regulation (EU) No 575/2013 (CRR)
- Topic
- Credit risk
- Article
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158, 159
- COM Delegated or Implementing Acts/RTS/ITS/GLs/Recommendations
- Not applicable
- Article/Paragraph
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N/A
- Type of submitter
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Credit institution
- Subject matter
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Offset of Additional Value Adjustments (AVA) against Expected Loss (EL) under Article 159
- Question
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Are AVAs arising from market risk for exposures to institutions (credit risk exposures) eligible for offset under Article 159 CRR?
- Background on the question
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This question follows on from EBA Q&As 933, 950 and 1835. Article 159 CRR states that ‘Institutions shall subtract the expected loss amounts calculated in accordance with Article 158 (5), (6) and (10) from the general and specific credit risk adjustments and additional value adjustments in accordance with Articles 34 and 110 and other own funds reductions related to these exposures’.
The response provided to Q&A 933 states that AVAs deducted from own funds should be included in the offset of AVAs against EL. Q&A 950 advises that AVAs related to expected loss amounts calculated in accordance with Article 158(5), (6) and (10) can be taken into account if related to these exposures. We are not clear from the response in Q&A 1835 whether only AVAs related to credit risk exposures can be included.
Where an institution calculates AVA (arising from market risk) under Article 9 of Regulation (EU) No. 2016/101, but relates to IRB credit risk exposures (i.e. institutions), that are not in default, it is unclear whether these AVAs can be included in the offset of AVA against Expected Loss.
- Submission date
- Final publishing date
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- Final answer
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Under Article 159 of Regulation (EU) No 575/2013 (CRR), “institutions shall subtract the expected loss amounts calculated in accordance with Article 158(5), (6) and (10) from the general and specific credit risk adjustments in accordance with Article 110 and additional value adjustments in accordance with Articles 34 and 105
110and other own funds reductions related to these exposures except for the deductions made in accordance with point (m) Article 36(1)”.
Hence, the Additional Value Adjustments (AVAs) to be included in the offset against expected losses (EL) are only those deducted from the own funds according to Article 34 CRR under the prudent valuation requirements of Article 105 CRR (Q&A 933), and referring to the credit risk exposures for which EL are calculated in accordance with Article 158(5), (6) and (10) CRR (Q&A 950). In other words, only AVAs associated to credit risk exposures due to counterparty default should be included within the offset in Article 159 CRR, as the offset under that Article is performed against expected loss amounts for credit risk.
Consequently, the AVAs to be included are limited to unearned credit spreads AVAs (Q&A 1835) and AVAs associated to credit risk exposures that are an element of unearned credit spreads in the sense of Article 12(2) of 2016/101. In particular, AVAs computed under Article 9 of Regulation (EU) No 2016/101, linked to market price uncertainty, are not in the scope of Article 159 CRR. - Status
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Final Q&A
- Answer prepared by
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Answer prepared by the EBA.
- Note to Q&A
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Update 26.03.2021: This Q&A has been updated in the light of the changes introduced to Regulation (EU) No 575/2013 (CRR).
Disclaimer
The Q&A refers to the provisions in force on the day of their publication. The EBA does not systematically review published Q&As following the amendment of legislative acts. Users of the Q&A tool should therefore check the date of publication of the Q&A and whether the provisions referred to in the answer remain the same.