ARXO-2026-0364 · Reported
Basel Framework: CRE32.10
The LGD* formula divides by E x (1+H_E), which is zero for an undrawn commitment whose exposure arises only through the CCF.
Consequence
Position: Facility with drawn E = 0, undrawn commitment 100, CCF 40%, collateral 50. Reading a: E = 0: weights undefined. Reading b: E taken as EAD 40: LGD* defined. Difference: Undefined vs defined (not executed)
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
- CRE32.10
- 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.
The LGD applicable to a collateralised transaction (LGD*) must be calculated as the exposure weighted average of the LGD applicable to the unsecured part of an exposure (LGD_{U}) and the LGD applicable to the collateralised part of an exposure (LGD_{S}).E_{U} = E ∙ (1+H_{E}) - E_{s}.
How to check it without Arxo's tools
- Open Basel Framework CRE32 (in force 2028-11-01, published 2025-10-28) and find CRE32.10. 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-2026-0364, https://arxo.io/findings/ARXO-2026-0364/ (status as of 2026-10-31). Data: ARXO-2026-0364.json.