Commitment amount at inception and off-balance-sheet amount for cross-limits
Section 3.5 of Part III of the Manual contains two good examples (No 7 and No 8) of how to report the commitment amount at inception and the off-balance-sheet amount when cross-limits exist. Those examples do, however, indicate that banks should allocate such values on the basis of their internal risk management policies and the principles set out in Section 3.4.3 of Part III of the Manual. What takes precedence in the event of a conflict between the bank’s internal risk management policy and Section 3.4.3?
Please also note that many banks’ internal policies may not contain rules on assigning off-balance-sheet amounts to instruments. Can you provide any additional guidance in this regard, or should reporting agents design assignment rules independently (presumably within the boundaries established by Section 3.4.3)?
Section 3.4.3 does indeed indicate a number of aspects that reporting agents should bear in mind when allocating off-balance-sheet amounts under a credit cross-limit for the purpose of reporting to AnaCredit.
The references made to internal risk management practices in that section are merely intended to enrich that fundamental rationale by including additional input which might be deemed of importance for the allocation of off-balance-sheet amounts given the reporting agent’s specific perspective regarding the instrument in question.
However, in the very unlikely event of a conflict between the fundamental rationale laid down in Section 3.4.3 and a bank’s own internal allocation system (e.g. in the event that, for some reason, the sum of all outstanding nominal amounts and off balance-sheet amounts reported by the reporting agent vis-à-vis the instruments under the credit cross-limit were not to equal the higher-level credit limit), Section 3.4.3 of the Manual should take precedence.
See also Off-balance-sheet items in the scope of AnaCredit Allocating off-balance-sheet amounts to instruments that do not comprise an undrawn amount Treatment of credit limit denominated in a currency other than the currency of the instrument Multi-product credit facilities with no specific credit sub-limits