ARXO-2026-0365 · Reported
Basel Framework: CRE32.63 (cross-ref to CRE20.92)
CRE32.63 refers to CRE20.92 for 100% CCF items, but CRE20.92 is the currency-mismatch multiplier and the 100% CCF list is in CRE20.95.
Consequence
Position: Retail undrawn commitment 100 that is a 100%-CCF item (CRE20.95), PD 1%, bank has approved own EAD estimates; own EAD estimate 40. Reading a: Follow CRE20.92 literally: it contains no CCF, so the 100% exclusion never triggers and own EAD 40 is allowed -> EAD 40. Reading b: Follow CRE20.95: item is at 100% CCF in the SA, so own estimates are not allowed -> EAD 100. Difference: EAD 60 (RWA scales proportionally)
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 CRE32 (in force 2028-11-01, published 2025-10-28)
- Place
- CRE32.63 (cross-ref to CRE20.92)
- 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.
provided the exposure is not subject to a CCF of 100% in the standardised approach (see CRE20.92)provided the exposure is not subject to a CCF of 100% in the foundation approach (see CRE32.33)
How to check it without Arxo's tools
- Open Basel Framework CRE32 (in force 2028-11-01, published 2025-10-28) and find CRE32.63 (cross-ref to CRE20.92). Compare the text with the quotation above. A copy is kept in this register: 1e1051609aa106ca-CRE32@2028-11-01~2025-10-28.txt (SHA-256
1e1051609aa106ca364a92ee01b845b3e06a570b48298b2cc019b5607be72ce8, copy of the official file). - 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
| Date | Institution | Channel | Reference |
|---|---|---|---|
| 2026-10-31 | Basel Committee on Banking Supervision | https://mail.google.com/mail/u/0/#sent/KtbxLthRTjRNkqRtWGvxMWmXhVdckfWkGV |
Responses
No response recorded.
History
- 2026-10-31Confirmed by Arxo
- 2026-10-31Entered in the register
- 2026-10-31Reported to Basel Committee on Banking Supervision (e-mail)
Cite this record
Arxo Law, Arxo Findings Register, ARXO-2026-0365, https://arxo.io/findings/ARXO-2026-0365/ (status as of 2026-10-31). Data: ARXO-2026-0365.json.