ARXO-2026-0382 · Reported
Basel Framework: LEV30.3 second example
LEV30.3 cites CAP10.19 for the IRB provisions-shortfall deduction from CET1, but CAP10.19 covers the opposite case (excess provisions in Tier 2); the deduction is in CAP30.13.
Consequence
Position: IRB bank, EL 100, eligible provisions 70, shortfall 30 Reading a: follow CAP10.19 literally: no shortfall deduction found there, so no 30 'deducted from CET1' basis for LEV30.3 -> exposure measure not reduced by 30 Reading b: read as CAP30.13: 30 deducted from CET1, so 30 may be deducted from exposure measure Difference: exposure measure differs by 30
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 LEV30 (in force 2023-01-01, published 2020-03-27)
- Place
- LEV30.3 second example
- 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.
CAP10.19 requires any shortfall in the stock of eligible provisions relative to expected loss amounts to be deducted from CET1 capital.Where the total expected loss amount exceeds total eligible provisions, banks must deduct the difference from Common Equity Tier 1.
How to check it without Arxo's tools
- Open Basel Framework LEV30 (in force 2023-01-01, published 2020-03-27) and find LEV30.3 second example. Compare the text with the quotation above. A copy is kept in this register: 5e23fb4d5fa87910-LEV30@2023-01-01~2020-03-27.txt (SHA-256
5e23fb4d5fa879107b86abc132543ed73ca8818845c245cf34fc2f1663f708d8, copy of the official file). - Open Basel Framework CAP30 (in force 2019-12-15, published 2019-12-15) and find CAP30.13. Compare the text with the quotation above. A copy is kept in this register: ab96c0ecb89252e7-CAP30@2019-12-15~2019-12-15.txt (SHA-256
ab96c0ecb89252e77768ab38fb4c7ffe7f84dc216571074674dde92e8afc7b4d, 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-2026-0382, https://arxo.io/findings/ARXO-2026-0382/ (status as of 2026-10-31). Data: ARXO-2026-0382.json.