Basel Framework: CRE20.35

CRE20.35 says the primary assets are 'listed in this paragraph', but the list sits in CRE20.34.

Consequence

Position: Cover pool of 110 against bonds of 100 including substitution cash 8 Reading a: Reading by reference to CRE20.34: substitution cash is additional collateral, not a primary asset Reading b: Literal 'this paragraph' has no list: substitution assets cannot be classified as additional or primary Difference: Classification of 8 of the pool (primary vs additional) unresolved

Proposed correction

Clarify or correct the cited passage so that the rule and its references give one result for the stated case.

Issued by

Basel Committee on Banking Supervision

Act

Basel Framework CRE20 (in force 2028-01-01, published 2025-06-10)

Place

CRE20.35

Record

Discrepancy

Class

Text of the act

Where it arose

The text of the act

Arxo's conclusion

Confirmed

Official text

Unchanged at last check

Last checked

2026-10-31

Evidence

Contradiction within the text. Quotations are verbatim from the official material; translations are ours and marked.

In addition to the primary assets listed in this paragraph, additional collateral may include substitution assets

In order to be eligible for the risk weights set out in CRE20.38, the underlying assets (the cover pool) of covered bonds as defined in CRE20.33 shall meet the requirements set out in CRE20.37 and shall include any of the following:

How to check it without Arxo's tools

1. Open Basel Framework CRE20 (in force 2028-01-01, published 2025-06-10) and find CRE20.35. Compare the text with the quotation above. A copy is kept in this register: e983544230ddd672-CRE20@2028-01-01~2025-06-10.txt (SHA-256 e983544230ddd672ef515a8b07ee9f2acc990c110ec9cd5146547e93a08b2c7f, copy of the official file).
2. The finding holds if the quoted passages read as shown and the comparison gives the result stated at the top of this page. If it does not, write to us with the record ID.

How this finding was made

AI models read the texts, built the examples and reviewed the findings.

Responsible institutions

• Basel Committee on Banking Supervision — maintains the Basel Framework

Reported to

Responses

No response recorded.

History

1. 2026-10-31Confirmed by Arxo
2. 2026-10-31Entered in the register
3. 2026-10-31Reported to Basel Committee on Banking Supervision (e-mail)

Cite this record

Arxo Law, Arxo Findings Register, ARXO-2026-0356, https://arxo.io/findings/ARXO-2026-0356/ (status as of 2026-10-31). Data: ARXO-2026-0356.json.