Question
Which set of seniority categories shall be utilised and how should they be ranked as the basis for offsetting the gross JTD amounts of short exposures and long exposures within the DRC calculations for non-securitisations?
Background on the question
Pursuant to CRR Article 325x(1) on the net jump-to-default amounts within the DRC calculations for non-securitisations, the gross JTD amounts of short and long exposures to the same obligor may be offset when the short exposures have the same seniority as, or lower seniority than, the long exposures. Yet, this CRR Article does not specify which set of seniority categories shall be utilised as the basis for the offsetting. It seems that a parallel can be drawn with the seniority categories already used for the assignment of LGDs to the exposures (specified in CRR Articles 325w(3) & 325w(6)) that are prescribed for calculating the gross JTD amounts set out in CRR Articles 325w(1) & (2). That interpretation would imply using the same seniority categories also for the offsetting in the context of Article 325x(1), namely: non-senior, senior, covered bond and equity. The ranking of the seniority should be done according to the LGD values assigned to the categories, e.g. the category with lowest LGD value ranks highest in the seniority. However, non-senior should rank higher than equity although the same LGD is applied.
Answer
Regulation (EU) No 575/2013 (CRR) does not prescribe the level of granularity at which the seniority of positions is to be assessed in the context of the DRC calculations for non-securitisations. However, a set of categories is used for a similar purpose in the context of Article 325w CRR.