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Advanced IRB Specification

Advanced IRB calculation with internal LGD and CCF estimates.

Regulatory Reference: CRR Articles 153-154, 158(5), 178

Test Group: CRR-C


Requirements Status

ID Requirement Priority Status
FR-1.4 A-IRB capital requirement: own-estimate PD, LGD, EAD with PD floors P0 Done
FR-1.5 A-IRB LGD floors per Basel 3.1 (CRE32) P1 Done
FR-1.8 Defaulted exposure A-IRB: K=max(0, LGD−BEEL) P0 Done
FR-1.9 Differentiated PD floors per Basel 3.1 P1 Done

Default Definition — Art. 178

A-IRB defaulted-exposure routing requires a companion beel (best estimate of expected loss under Art. 158(5)). The Art. 178 two-limb default trigger (unlikeliness-to-pay and 90 DPD), UTP indicators, materiality threshold, and cure/probation rules are documented in the shared Default Definition (Art. 178) specification.


Overview

A-IRB uses the same capital requirement formula and correlation functions as F-IRB, but the bank provides its own estimates for LGD and (optionally) maturity and CCF, rather than using supervisory values.

Key Differences from F-IRB

Parameter F-IRB A-IRB (CRR) A-IRB (Basel 3.1)
PD Bank estimate (floored) Bank estimate (floored) Bank estimate (floored)
LGD Supervisory Bank estimate, portfolio-level floors only Bank estimate, per-exposure input floors
CCF Supervisory Bank estimate Bank estimate
Maturity Supervisory (2.5y default) Bank estimate (clamped 1-5y) Bank estimate (clamped 1-5y)

LGD Floors

CRR Portfolio-Level LGD Floors (Art. 164(4))

CRR Art. 164(4) (as amended by CRR2, Regulation 2019/876) imposes portfolio-level LGD floors for retail exposures secured by immovable property:

Portfolio Minimum Exposure-Weighted Average LGD Reference
Retail secured by residential immovable property 10% Art. 164(4) para 1
Retail secured by commercial immovable property 15% Art. 164(4) para 2

These are not per-exposure input floors — they require that the exposure-weighted average LGD across the entire retail property portfolio does not fall below the threshold. Exposures benefiting from central government guarantees are excluded from the calculation.

Art. 164(5)–(8) grant the PRA power to set higher minimum LGD values based on periodic assessment of loss experience data, forward-looking market developments, and financial stability concerns.

Code Divergence (D3.38)

Under CRR the rulepack disables A-IRB LGD floors entirely — the cited airb_lgd_floor Feature is enabled=False and the lgd_floors bundle is all-zero (src/rwa_calc/rulebook/packs/crr.py), so the engine applies no own-estimate LGD floor (CRR Art. 164 lets A-IRB firms model LGD freely). The CRR Art. 164(4) portfolio-level (exposure-weighted-average across all qualifying retail exposures) floors are not implemented; the engine's per-exposure floor branch (engine/irb/formulas.py, gated on the airb_lgd_floor Feature) is the Basel-3.1 mechanism only. Implementing the CRR portfolio-level test would require a post-aggregation validation step, which is not currently in the pipeline.

Distinction from Basel 3.1

Basel 3.1 Art. 164(4) replaces the CRR portfolio-level mechanism with per-exposure input floors (see below). Under Basel 3.1, each individual exposure's LGD is floored before entering the capital formula — a fundamentally different approach from CRR's portfolio-average test.

Basel 3.1 Per-Exposure LGD Floors

Under Basel 3.1, the following per-exposure input floors apply:

Corporate A-IRB LGD Floors (Art. 161(5))

Art. 161(5) has two limbs. Point (a) sets a flat 25% floor for unsecured exposures and for exposures where the firm chooses not to take recognised funded credit protection into account. Point (b) covers secured and partially secured exposures where the firm does take the protection into account: the floor is the Art. 230 (single collateral type) / Art. 231 (multiple types) LGD* value, computed with 25% substituted for LGDU (Art. 161(5)(b)(iii)) and the following LGDS values (Art. 161(5)(b)(iv)):

Collateral Type LGDU / LGDS
Unsecured (Senior) — LGDU 25%
Financial collateral 0%
Receivables 10%
Commercial real estate 10%
Residential real estate 10%
Other physical 15%

A partially secured exposure is therefore floored on the blend, not on the flat 25% and not on the bare collateral-type LGDS. For a GBP 10m corporate loan with GBP 4m of recognised financial collateral the floor is 0.6 x 25% + 0.4 x 0% = 15%.

The weights are shares of the Art. 230(1) exposure basis E' = E x (1 + HE), where E is ead_for_crm — the CCF=100% exposure value (Art. 223(4)) — and HE is the exposure's own volatility haircut (Art. 223(5), non-zero only on securities-lending rows). It is not the post-CCF ead_gross: for a GBP 1m undrawn committed facility at a 40% CCF with GBP 200k of recognised cash, the floor is 25% x 800k/1m = 20%, not the 25% x 200k/400k = 12.5% a post-CCF divisor gives. Every LGDS lies below every LGDU, so the smaller divisor over-weights the secured share and understates the floor.

Recorded decision: what constitutes the Art. 161(5) election

The engine reads the presence of eligible recognised collateral (total_collateral_for_lgd > 0 after the Art. 199 / 207-210 eligibility gates and the Art. 231 waterfall) as the firm choosing to take funded credit protection into account, i.e. as limb (b). There is currently no input by which a firm can elect limb (a) while still supplying that collateral — to sit on the flat 25% it must withhold the collateral row or fail its eligibility flags. Deliberate: the (b) blend is bounded above by LGDU, so such an election could only ever lower the floor, and an unflagged election would be indistinguishable from missing data.

Correction: No 50% Subordinated Floor for Corporate

The 25% floor applies to all corporate unsecured exposures (both senior and subordinated) under Art. 161(5). The "50% subordinated" floor does not exist for corporate A-IRB — the 50% floor applies to retail QRRE unsecured exposures (see below).

Retail A-IRB LGD Floors (Art. 164(4))

Retail Sub-Class Collateral LGD Floor Reference
Residential real estate (RRE) RRE secured 5% Art. 164(4)(a)
QRRE (unsecured) None 50% Art. 164(4)(b)(i)
Other retail (unsecured) None 30% Art. 164(4)(b)(ii)
Any retail (non-RRE collateral) Other collateral Blended (see below) Art. 164(4)(c)

Retail "Other Secured" LGD Floor — Art. 164(4)(c)

For retail exposures secured by collateral other than RRE, the LGD floor is a blended value combining the secured collateral floor (LGDS) and the unsecured floor (LGDU = 30%), weighted by the secured and unsecured portions of the exposure — the same structure as the Foundation Collateral Method in Art. 230.

The LGDS values by collateral type are:

Collateral Type LGDS (Secured Floor)
Financial collateral 0%
Receivables 10%
Immovable property (non-RRE) 10%
Other physical 15%

Where no split between secured/unsecured portions is available, the conservative approach is to apply the relevant collateral-type LGDS directly (or LGDU=30% if unsecured).

Implementation: src/rwa_calc/engine/irb/formulas.py_lgd_floor_blended_expression() computes the weighted-average floor using the crm_alloc_* columns from the Art. 231 sequential waterfall. The formula: LGD_floor = (E_unsecured / E') × LGDU + Σ_i (E_i / E') × LGDS_i, with E' = ead_for_crm × (1 + HE) shared with the LGD itself via engine/crm/expressions.py::lgd_star_exposure_basis_expr(). The same expression serves both limbs — Art. 161(5)(b) for corporates and institutions and Art. 164(4)(c) for retail — because the LGDS tables are identical and only LGDU differs: 50% retail_qrre, 30% retail_other, 25%* every other class. It applies to every exposure class except retail_mortgage (flat 5% per Art. 164(4)(a)) once recognised collateral is present, and returns null — deferring to the flat / single-type floor — when nothing is recognised or the allocation columns are absent.

Scope of Corporate vs Institution LGD Floors

Art. 161(5) is headed "LOSS GIVEN DEFAULT (LGD): CORPORATES AND INSTITUTIONS" and its opening words are "for exposures to corporates and institutions". In practice institution exposures are restricted to F-IRB under Art. 147A(1)(c) and all financial sector entities under Art. 147A(1)(e), so the A-IRB floors rarely bind there — but the implementation still routes institution through the same 25% LGDU path rather than carving it out. Art. 161(4) is "[Note: Provision left blank]" in PRA PS1/26 — only Art. 161(5) is active.

RRE LGD Floor

The PRA PS1/26 retail RRE LGD floor is 5% per Art. 164(4)(a). This was changed from 10% in the near-final rules to 5% in the final PS1/26 rules. BCBS CRE32.25 also specifies 5%.

Implementation Status

All four Art. 164(4) retail LGD floors are fully implemented (P1.87 complete). Floor values are cited entries in the rulepack (src/rwa_calc/rulebook/packs/b31.py), resolved per run via resolve("b31", date); the Art. 164(4)(c) blended formula reads them in engine/irb/formulas.py (_lgd_floor_blended_expression). The blended formula uses crm_alloc_* columns from the Art. 231 waterfall to compute the weighted secured/unsecured floor, and since P1.248 covers the Art. 161(5)(b) corporate / institution limb as well as retail. Dedicated tests in tests/unit/test_lgd_floor_blended.py and tests/acceptance/basel31/test_p1_248_art_161_5_partially_secured_lgd_floor.py.

Deferred: the blend's deny-list is ["retail_mortgage"] only, so residential_mortgage / commercial_mortgage would blend if they ever reached an IRB row — unreachable today, as both are SA re-splitter outputs (PS1/26 Art. 124C-124K) and never carry an IRB approach.

FI Scalar

The 1.25x correlation multiplier for large/unregulated financial sector entities applies equally to A-IRB and F-IRB (Art. 153(2), CRE31.5). The LFSE (large financial sector entity) total-assets threshold is EUR 70 billion under CRR Art. 142(1)(4) and GBP 79 billion under Basel 3.1 (PS1/26 Glossary p. 78, with Note "corresponds to Article 142(1)(4) of CRR"). The 1.25 factor is applied to the asset correlation coefficient R, which has a non-linear effect on the capital requirement K.

Distinct from Art. 147A approach restrictions

The correlation multiplier (LFSE total-assets threshold, Art. 153(2)) is not the same as the Art. 147A(1)(e) large corporate threshold (GBP 440m revenue), which restricts A-IRB eligibility but does not affect the correlation formula. See F-IRB Specification for full details.

Calculation

The capital requirement formula, correlation functions, maturity adjustment, and RWA computation are identical to F-IRB. See F-IRB Specification for full details.

Post-Model Adjustments (Basel 3.1)

Mortgage Risk Weight Floor (Art. 154(4A)(b))

Basel 3.1 introduces a minimum risk weight floor for UK residential property exposures under IRB:

  • Regulatory floor: 10% per Art. 154(4A)(b) for non-defaulted IRB residential mortgage exposures
  • Scope: All non-defaulted IRB exposures secured by residential immovable property
  • Formula: floor_adjustment = max(0, floor_rw - modelled_rw) × EAD
  • RWEA: RWEA_adjusted = RWEA_modelled + floor_adjustment
  • Reported: COREP column 0253 (adjustment for mortgage RW floor)
  • Configurable: Via PostModelAdjustmentConfig.mortgage_rw_floor (default should be 10%)

Correction

The regulatory floor is 10%, not 15%. Art. 154(4A)(b) specifies the 10% minimum risk weight for residential property exposures under A-IRB. The previous 15% was an early implementation assumption.

General Post-Model Adjustments (Art. 146(3) / Art. 158(6A))

Art. 146(3) establishes the root obligation: firms using IRB must apply post-model adjustments to compensate for known model deficiencies. Art. 158(6A) specifies the EL monotonicity constraint. Firms must apply PMAs to both RWEA and EL:

  • PMA on RWEA: RWEA_adjusted = RWEA_modelled × (1 + pma_rwa_scalar)
  • PMA on EL: EL_adjusted = EL_modelled × (1 + pma_el_scalar)
  • Reported: COREP column 0252 (adjustment for post-model adjustments)

Adjustment Sequencing (Art. 153(5A) / Art. 154(4A))

Art. 154(4A) prescribes the following sequential order for RWEA adjustments:

  1. Mortgage RW floor — Art. 154(4A)(b): applied first to establish the post-floor RWEA base
  2. General PMA scalars and unrecognised-exposure adjustments — Art. 154(4A)(a): applied to the post-floor RWEA from step 1

Sequencing is mandatory

The mortgage floor (step 1) must be computed before general PMAs (step 2) are applied. PMAs scale the already-floored RWEA, not the raw modelled RWEA.

EL monotonicity — Art. 158(6A)

PMA adjustments to Expected Loss can only increase EL, never decrease it. The PMA EL scalar must satisfy pma_el_scalar ≥ 0. An adjustment that would reduce EL below the pre-PMA model output is not permitted.

Implementation Status

Sequential ordering (mortgage floor before PMA scalars) and EL monotonicity are both implemented.

Double Default Removal (Basel 3.1)

CRR Art. 153(3) provided a double-default treatment for guaranteed exposures. Under PRA PS1/26, Art. 153(3) is "[Note: Provision left blank]" — the double-default treatment has been removed. Any exposures that previously benefited from double-default must fall back to standard parameter substitution (Art. 236) or risk weight substitution (Art. 235).

A-IRB CCF Restrictions (Basel 3.1)

Under Basel 3.1, own CCF estimates are only permitted for revolving facilities (Art. 166D). All non-revolving off-balance sheet items must use SA CCFs from Table A1. See CCF Specification for full details including the 50% floor on A-IRB CCF estimates.

Key Scenarios

Scenario ID Description Key Parameters
CRR-C1 Corporate A-IRB with own LGD estimate PD modelled, LGD=35% (own estimate), M=2.5y
CRR-C2 Retail A-IRB with own PD and LGD estimates PD=0.30%, LGD=15% (own estimate)
CRR-C3 Specialised lending A-IRB — project finance SL routed to A-IRB (with permission) instead of slotting

Additional spec scenarios validated through the above and B31-C group:

  • Internal CCF: Own-estimate CCF used for revolving facilities (validated within C1/C2 pipeline)
  • FI scalar (1.25x): Correlation uplift for large/unregulated FSEs (validated through B31-B7 and pipeline tests)
  • A-IRB vs F-IRB comparison: Same exposure with supervisory vs own LGD (validated through comparison test group M3.1)

Acceptance Tests

Group Scenarios Tests Pass Rate
CRR-C: Advanced IRB C1–C3 7 100% (7/7)