NOR GVT CRR3 EEA Position Note


On Nov. 27, NOR GVT issued EEA position note on Reg 2024/1623.


  • NOR GVT issued EEA position note on Regulation 2024/1623 i.e. the CRR3.
  • The reg is being considered for inclusion in EEA agreement by the EEA/EFTA states.
  • Follows EC Oct. 2024 issued Reg 2024/2795 re CRR3 postponement, see #234272.
  • Follows EU CNCL Jun. 2024 issued Reg 2024/1623 and Dir 2024/1619, see #177370.
  • NOR Situation
  • The note recalls CRR was incorporated into EEA Agreement and implemented in Norwegian law in Regulation 1997/2014 (CRR/CRD regulations) §2 first paragraph.
  • CRRs implemented by incorporation (reference to EU regs) in CRR/CRD Regulation 197/2014 §2, CRR3 is envisaged to follow the same path.
  • CRR3 has more risk-sensitive standard method, restricts IRB use for certain portfolios.
  • Banks with significant proportion of mortgages in portfolio that use standard method, have lower capital requirements for mortgages with low to moderate LTV ratio.
  • Lower capital requirements for loans with mortgages on commercial property can also contribute to overall lower capital requirements for the standard method banks.
  • IRB banks with significant lending to large enterprises may have stricter capital requirements when have to use regulatory LGD estimates instead of own estimates.
  • Banks that are not permitted to use their own LGD estimates will have lower capital requirements as the regulatory LGD estimates are reduced.
  • Other IRB banks are expected to have lower capital requirements as a result of the removal of adjustment factor in risk weighting formula.
  • New capital requirement floor for IRB banks not binding in 1st years of transition scheme, assumed to have modest effect for most banks after transition ends in 2032.
  • Changes in weighting rules for operational risk expected to reduce capital requirement.
  • Rules changes for market, CVA risk expected to have less significance for NOR banks.
  • Yet, overall effects on capital requirements is uncertain, affected by national choices.
  • Introducing requirement to report information to be made public to EBA will mean that largest Norwegian banks must report to the EBA.
  • Dec. 2024 Regulation and Decision
  • On Dec. 9, 2024, NOR GVT issued FOR-2024-12-06-2952 amending Reg 1097/2014.
  • S2, para 1, new k refers to Reg 2024/1623, S5 title is Common Equity Tier 1 capital.
  • Further amendments are made; the regulation will enter into force at a later date.
  • EEA Decision 291/2024 of Dec. 6, 2024 amended Annex IX (Financial services) to EEA Agreement to include in Point 14a (Reg 575/2013) reference to Reg Reg 2024/1623.
  • In force on Jan. 1, 2025, if all notifications under art 103.1 EEA Agreement are made.
  • Dec. 9, 2024 IRB Floor
  • On Dec. 9, 2024, NOR GVT published FOR-2024-12-06-2951 regulations on changes in regulations on capital requirements and implementation of the CRR/CRD regulations (IRB floor for risk weighting of property loans), in force on Jan. 1, 2025.

Regulators EFTA; NOR GVT
Entity Types Bank; MG Orig
Reference OG 2024-1332, 12/9/2024; FOR-2024-12-06-2951, 12/6/2024; OG 2024-1333, FOR-2024-12-06-2952, 12/9/2024; Dec 291/2024, 12/6/2024; Nt 11/27/2024; Reg 1097/2014; CRR/CRD Reg; CRR3 Reg 2024/1623; EEA Agreement; Citation: FOR-2024-12-06-2952; FOR-2024-12-06-2951;
Functions Compliance; Financial; Legal; Operations; Reporting; Risk; Technology
Countries Norway
Category
State
Products Banking; Loan; Mortgage
Regions EMEA
Rule Type Final
Rule Date 11/27/2024
Effective Date 1/1/2025
Rule Id 235131
Linked to Rule :234272
Reg. Last Update 12/9/2024
Report Section EU

Last substantive update on 12/12/2024