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Real Estate Exposures

Real estate exposures are credit exposures secured by mortgages on residential or commercial immovable property. Under Basel 3.1 (PRA PS1/26 Art. 124–124L), real estate becomes a standalone exposure class (Art. 112 Table A2 priority 7) with dedicated loan-splitting and LTV-banded risk-weight tables, replacing the CRR Art. 125/126 regime.

Definition

A real estate exposure is any credit exposure secured by a charge over residential or commercial immovable property. Under Basel 3.1, the framework distinguishes three treatment buckets via the Art. 124 routing rule:

Bucket Article Treatment
Regulatory RE — passes Art. 124A six-criterion gate Art. 124(1) Loan-splitting (Art. 124F/H) or income-producing tables (Art. 124G/I)
Other RE — fails Art. 124A but is not ADC Art. 124(2) Art. 124J fallback (150% income-dependent / counterparty RW otherwise)
ADC — acquisition / development / construction Art. 124(3) Art. 124K (150% standard, 100% qualifying residential)

RE Class Distinct from RETAIL_MORTGAGE

Residential-mortgage-secured exposures to retail counterparties that meet the Art. 123 retail criteria are routed through RETAIL_MORTGAGE (CRR Art. 125: 35% on the ≤80% LTV portion, 75% above). Real-estate-secured exposures to non-retail counterparties (corporates, institutions, large landlords, SMEs above the retail threshold) enter the SA real-estate loan-splitter via RESIDENTIAL_MORTGAGE / COMMERCIAL_MORTGAGE instead. See Retail Exposures for the retail-class boundary.

Routing (Art. 124(1)–(3))

flowchart TD
    A[RE Exposure] --> B{is_adc?}
    B -->|Yes| C[Art. 124K — 150% / 100%]
    B -->|No| D{Passes Art. 124A six criteria?}
    D -->|No| E[Art. 124J — Other RE]
    D -->|Yes| F{is_income_producing / materially dependent?}
    F -->|Yes — RESI| G[Art. 124G — Whole-loan, Table 6B]
    F -->|Yes — CRE| H[Art. 124I — Whole-loan, 2-band]
    F -->|No — RESI| I[Art. 124F — Loan-splitting 20%/cpty]
    F -->|No — CRE| J[Art. 124H — Loan-splitting 60%/cpty]

The ADC check is evaluated first (Art. 124(3)) — Art. 124A(1) opens "A real estate exposure is a regulatory real estate exposure if it is not an ADC exposure and all the following requirements are met". ADC therefore never enters the Art. 124F–124J channel regardless of LTV, occupancy, or qualifying-criteria status.

Details: See Real Estate — Framework Scope (Art. 124) for the full routing decision tree, mixed-use Art. 124(4) split, and CRR comparison.

The Six Qualifying Criteria — Art. 124A(1)

A real estate exposure is regulatory RE (and so eligible for the preferential Art. 124F–124I tables) only if it satisfies all six of the following. Failing any one drops the exposure to Art. 124J.

Criterion Requirement Reference
(a) Property condition Property is not held for development/construction, OR development is complete, OR it is a self-build exposure Art. 124A(1)(a)(i)–(iii)
(b) Legal certainty Charge is enforceable in all relevant jurisdictions AND collateral can be realised within a reasonable period after default Art. 124A(1)(b)
(c) Charge conditions One of the conditions in Art. 124A(2) is met (perfected first-rank charge, or stacked junior charge with full transparency) Art. 124A(1)(c)
(d) Valuation Property value obtained per Art. 124D (qualifying valuation, independent, at or below market) Art. 124A(1)(d)
(e) Borrower independence Property value does not materially depend on borrower performance Art. 124A(1)(e)
(f) Insurance monitoring Institution has procedures to monitor adequate property insurance against damage Art. 124A(1)(f)

The calculator consumes the firm's pre-evaluated is_qualifying_re flag — it does not re-derive the six tests in-engine.

Details: See Real Estate — Qualifying Criteria (Art. 124A) for the full criterion-by-criterion breakdown, the self-build carve-out under (a)(iii), and the Art. 124A(2) charge-condition list.

Hard-Test vs Soft-Test: Material Dependency (Art. 124E)

Within regulatory RE, Art. 124E classifies the exposure between two treatment tracks:

Track Test result Track
Hard test (loan-splitting) Property cash flows are NOT a material source of repayment Art. 124F (RESI) / Art. 124H (CRE)
Soft test (whole-loan, LTV-banded) Property cash flows ARE a material source of repayment Art. 124G (RESI) / Art. 124I (CRE)

Residential default rule (Art. 124E(1)): A residential RE exposure is presumed not materially dependent on the property's cash flows. The presumption flips to "materially dependent" only where the borrower has more than three financed residential properties, in which case all subsequent properties enter the income-producing track.

Commercial own-use test (Art. 124E(6)): A commercial RE exposure is not materially dependent if the property is used predominantly for the borrower's own business purpose. Owner-occupied office, factory, or warehouse loans take the loan-splitting track; let-out CRE (rent-financed) takes the income-producing track.

The calculator consumes is_income_producing to route between the two tracks.

Details: See Material Dependency Classification (Art. 124E) for the full default rule, the three-property limit, the own-use test, and re-assessment triggers (Art. 124E(5)/(7)).

LTV Definition — Art. 124C

The regulatory LTV used for all loan-splitting thresholds and band lookups is:

LTV = loan_amount / property_value

Numerator (Art. 124C(2)–(3)):

  • Outstanding loan balance + undrawn committed amount of the mortgage loan
  • Plus all loans secured by charges ranking ahead of or pari passu with the institution's charge (Art. 124C(3) — prior charges stacking)
  • Excluding credit risk adjustments, own-funds reductions, and funded/unfunded credit protection (single exception: pledged-deposit on-balance-sheet netting may be deducted)
  • Where ranking information is incomplete, the institution must treat other charges as pari passu — a conservative assumption that increases LTV

Denominator (Art. 124C(4)): Property value per Art. 124D qualifying valuation, with revaluation triggers at >10% market decline and a GBP 2.6m / 5%-of-own-funds threshold for transitional pre-2027 exposures.

Two input fields drive the calculator's LTV logic:

Field Description
property_ltv Total stacked LTV including all Art. 124C(2)–(3) components — used for risk-weight band lookup
prior_charge_ltv LTV contribution of prior/pari passu charges only — used to reduce the 55% loan-splitting threshold under Art. 124F(2) / 124H(2) and to trigger the 1.25× junior-charge multiplier under Art. 124G(2)

Details: See Real Estate — LTV Definition (Art. 124C) for the full numerator components, prior-charges worked example, and Art. 124D valuation rules including the self-build floor.

Risk Weights — Residential RE (Art. 124F–124G)

Loan-Splitting — Owner-Occupied / Non-Income-Producing (Art. 124F)

Exposure is split into a secured portion (up to 55% of property value) and a residual:

Portion Risk Weight Reference
Secured (up to 55% of property value) 20% Art. 124F(1)
Residual (above 55%) Counterparty RW per Art. 124L Art. 124F
secured_share = min(1.0, 0.55 / LTV)
RW_blended = 0.20 × secured_share + counterparty_RW × (1.0 - secured_share)

Junior charges (Art. 124F(2)): Where prior-ranking charges held by other lenders exist, the 55% threshold is reduced by the prior_charge_ltv before computing secured_share. This shrinks the 20%-weighted portion.

Income-Producing — Whole-Loan, Table 6B (Art. 124G)

Materially dependent on property cash flows (e.g. buy-to-let, multi-unit rental to a single landlord). Single risk weight on the whole exposure:

LTV Band Risk Weight
≤ 50% 30%
50–60% 35%
60–70% 40%
70–80% 50%
80–90% 60%
90–100% 75%
> 100% 105%

Junior charge multiplier (Art. 124G(2)): Whole-loan RW × 1.25 for LTV > 50% where prior-ranking charges held by other lenders exist. The multiplied RW is not capped at the table maximum of 105% — e.g. a 105% × 1.25 = 131.25% weight is the correct outcome at LTV > 100% with junior charges.

Risk Weights — Commercial RE (Art. 124H–124I)

Loan-Splitting — Owner-Occupied (Art. 124H(1))

Borrower predominantly uses the property for its own business (Art. 124E(6)):

Portion Risk Weight Reference
Secured (up to 55% of property value) 60% Art. 124H(1)(a)
Unsecured (above 55%) Counterparty RW per Art. 124L Art. 124H(1)(b)

55% threshold, not 60%

The loan-splitting threshold under Art. 124H(1)(a) is 55% of property value (the same threshold as residential Art. 124F). The 60% is the risk weight on the secured portion, not the LTV band.

Income-Producing — Whole-Loan, 2-Band (Art. 124I)

Materially dependent on property cash flows (e.g. multi-tenant let CRE, hotel financed by room revenue):

LTV Risk Weight
≤ 80% 100%
> 80% 110%

PRA Deviation from BCBS

BCBS CRE20.86 uses a 3-band table (≤60%: 70%, 60–80%: 90%, >80%: 110%). The PRA simplifies to 2 bands with higher weights for the lower LTV tiers.

Junior charge treatment (Art. 124I(3)): Where prior-ranking charges held by other lenders exist, the income-producing CRE table is replaced by absolute weights (not a multiplier on Art. 124I(1)/(2)):

LTV Band RW with junior charges
≤ 60% 100%
> 60% and ≤ 80% 125%
> 80% 137.5%

Large Corporate CRE — Art. 124H(3)

For non-natural-person, non-SME borrowers with non-cash-flow-dependent CRE, a third path applies on top of loan-splitting:

RW = max(60%, min(counterparty_RW, income_producing_RW))

Counterparty Risk Weights — Art. 124L

The unsecured residual under loan-splitting (Art. 124F / 124H) is weighted using:

Counterparty Type Counterparty RW
Natural person (non-SME) 75%
Retail-qualifying SME 75%
Other SME (unrated) 85%
Social housing / cooperative max(75%, unsecured RW)
Other (corporate, institution) Standard unsecured counterparty RW

Details: See Real Estate — Residential and Real Estate — Commercial for the full risk-weight derivation, including worked examples and the Art. 124L counterparty table.

ADC Exposures — Art. 124K

ADC (Acquisition, Development, and Construction) exposures are loans to corporates or SPEs (not natural persons) financing land acquisition for development/construction, or financing the development/construction itself:

Scenario Risk Weight Reference
Standard ADC 150% Art. 124K(1)
Qualifying residential ADC 100% Art. 124K(2)

The 100% concession is residential-only and requires both:

  • (a) Prudent underwriting — including for any RE used as security
  • (b) At least one of:
    • (i) Pre-sales/pre-leases: Legally binding contracts where the buyer/tenant has made a substantial cash deposit subject to forfeiture, amounting to a significant portion of total contracts, OR
    • (ii) Borrower equity at risk: Substantial equity contribution

Two ADC input flags

The calculator uses two boolean inputs: is_adc (routes to Art. 124K) and is_presold (asserts Art. 124K(2) qualifying conditions are met). The PRA does not define quantitative thresholds for "substantial" or "significant portion" — these are firm-level judgements subject to supervisory review.

Details: See Real Estate — ADC Exposures (Art. 124K) for the full qualifying conditions, CRR comparison (no Art. 124K under CRR; Art. 128 high-risk omitted by SI 2021/1078), and key scenarios.

Other RE — Art. 124J (the failing-Art. 124A bucket)

Where any Art. 124A criterion fails (and the exposure is not ADC):

Sub-bucket RW Reference
Income-dependent (any property type) 150% Art. 124J(1)
Residential, not income-dependent Counterparty RW per Art. 124L Art. 124J(2)
Commercial, not income-dependent max(60%, counterparty RW) Art. 124J(3)

The is_qualifying_re input flag drives the Art. 124J vs Art. 124F–124I split. When False, the exposure is routed to Art. 124J before the standard hard-test/soft-test branching.

Mixed-Use Loans — Art. 124(4)

A mixed real estate exposure is a single exposure secured by both residential and commercial property (e.g., a mixed-use building with shops on the ground floor and flats above). Art. 124(4) requires proportional splitting by collateral value:

Both parts qualify under Art. 124A Either part fails Art. 124A
RESI portion → Art. 124F/G; CRE portion → Art. 124H/I Both parts → Art. 124J (all-or-nothing gate)

Worked example: GBP 2,000,000 loan secured by mixed-use property valued at GBP 2,500,000 (RESI 60%, CRE 40%). LTV = 80% on the aggregate. Both parts qualify:

Notional component EAD Property value LTV Treatment
RESI 60% 1,200,000 1,500,000 80% Art. 124F: 20% on first 55% × 1,500,000 = 825,000; residual 375,000 at counterparty RW
CRE 40% 800,000 1,000,000 80% Art. 124H(1): 60% on first 55% × 1,000,000 = 550,000; residual 250,000 at counterparty RW

Mixed-Use Schema Gap (D3.59) — Loader-Boundary Workaround

The current input schema exposes a single property_value and property_type per exposure row, with no native mechanism to declare a mixed-property exposure. The Art. 124(4) proportional split is therefore not applied automatically — the calculator routes each row exclusively through either the RESI (Art. 124F–124G) or CRE (Art. 124H–124I) chain based on the single property_type flag.

Workaround: Pre-split the exposure into two input rows at the loader boundary — one with property_type = "residential" and property_value = V_RESI, one with property_type = "commercial" and property_value = V_CRE — each with EAD = total_EAD × (V_part / V_total) and is_qualifying_re reflecting that part's own Art. 124A status. This matches the regulation's outcome but places the split-logic obligation on the firm. See D3.59 in DOCS_IMPLEMENTATION_PLAN.md.

Details: See Mixed Real Estate Split (Art. 124(4)) for the full all-or-nothing gate, worked example, and CRR comparison.

Calculation Examples

Example 1 — Owner-Occupied House (Loan-Splitting, Art. 124F)

Exposure:

  • £250,000 mortgage to an individual borrower
  • Property value: £350,000 → LTV = 71.4%
  • Owner-occupied (not income-producing)
  • First charge, no prior charges (prior_charge_ltv = 0)
  • Counterparty RW (Art. 124L): 75% (natural person)

Calculation:

secured_share = min(1.0, 0.55 / 0.714) = 0.770
RW = 20% × 0.770 + 75% × (1.0 - 0.770) = 15.4% + 17.25% = 32.65%
RWA = 250,000 × 32.65% = 81,625

Example 2 — Buy-to-Let (Income-Producing, Art. 124G)

Exposure:

  • £400,000 mortgage to a portfolio landlord with 5 financed BTL properties (Art. 124E(1) three-property limit breached → income-producing track)
  • Property value: £500,000 → LTV = 80%
  • Materially dependent on rental cash flows

Calculation:

LTV 70–80% band → RW = 50% (Table 6B)
RWA = 400,000 × 50% = 200,000

Example 3 — Owner-Occupied Office (CRE Loan-Splitting, Art. 124H(1))

Exposure:

  • £2,000,000 loan to an SME (turnover £30m → Art. 124L "other SME" → counterparty RW 85%)
  • Office property used for borrower's own business; value £3,000,000 → LTV = 66.7%
  • First charge

Calculation:

secured_share = min(1.0, 0.55 / 0.667) = 0.825
RW = 60% × 0.825 + 85% × (1.0 - 0.825) = 49.5% + 14.875% = 64.375%
RWA = 2,000,000 × 64.375% = 1,287,500

Example 4 — Income-Producing CRE with Junior Charge (Art. 124I(3))

Exposure:

  • £5,000,000 loan secured by a multi-tenant let office; property value £6,500,000
  • LTV = 76.9%
  • Senior lender holds a £1,500,000 prior charge (prior_charge_ltv = 23.1%)

Calculation:

LTV > 60% and ≤ 80% with junior charge → Art. 124I(3)(b) absolute weight = 125%
RWA = 5,000,000 × 125% = 6,250,000

Example 5 — Qualifying Residential ADC (Art. 124K(2))

Exposure:

  • £10,000,000 development loan to an SPE building 50 residential units
  • 60% pre-sold under legally binding contracts with substantial forfeitable deposits
  • Prudent underwriting confirmed by credit committee

Calculation:

is_adc = True, is_presold = True → Art. 124K(2) qualifying residential ADC
RW = 100% (vs 150% for non-qualifying)
RWA = 10,000,000 × 100% = 10,000,000

CRR vs Basel 3.1 — Key Differences

Aspect CRR (until 31 Dec 2026) Basel 3.1 (from 1 Jan 2027)
Framework structure Art. 125 (residential) + Art. 126 (commercial) Art. 124–124L unified RE class
Residential RW (retail) 35% on ≤80% LTV portion, 75% above (Art. 125) LTV bands 20%–105% per Art. 124F/G
Commercial RW 50% if Art. 126(2) conditions met, else counterparty RW Loan-splitting 60%/cpty (Art. 124H) or 100/110% (Art. 124I)
Qualifying-criteria gate Art. 125(2) / 126(2) conditions Art. 124A six-criterion gate
ADC No standalone class (Art. 128 high-risk omitted by SI 2021/1078) Art. 124K — 150% standard / 100% qualifying
Income-producing distinction Implicit in Art. 126 own-use test Explicit Art. 124E material-dependency test
Mixed-use split Implicit (predominant security) Explicit Art. 124(4) proportional split
Output floor N/A RE exposures contribute to 72.5% SA-equivalent floor

Details: See Key Differences — Real Estate for the full CRR vs Basel 3.1 comparison and transitional treatment.

Underwriting Standards — Art. 124B

Article 124B is a governance precondition for originating real estate exposures applicable to all RE — regulatory RE, other RE, and ADC. Institutions must operate an underwriting policy that, at a minimum, requires assessment of the borrower's ability to repay.

This is not a calculator input — compliance is evidenced by underwriting policy documentation, credit-committee approval records, and PRA supervisory review (CRD Art. 79, SS31/15 ICAAP). A breach does not automatically reclassify exposures into Art. 124J; supervisory enforcement is the remedy.

Details: See Real Estate — Underwriting Standards (Art. 124B) for the full firm-governance scope and relationship to other Art. 124-series provisions.

Input Schema Summary

Field Type Description
is_adc bool Routes to Art. 124K; bypasses LTV-band logic
is_presold bool Together with is_adc=True, applies Art. 124K(2) qualifying-residential 100% RW
is_qualifying_re bool Asserts the six Art. 124A(1) criteria are met; False routes to Art. 124J
is_income_producing bool Routes to whole-loan tables (Art. 124G/I) instead of loan-splitting (Art. 124F/H)
property_type enum "residential" or "commercial" — drives RESI vs CRE branching
property_value Decimal Art. 124D-compliant qualifying valuation (firm-supplied)
property_ltv Float64 Total Art. 124C(1)–(3) stacked LTV (incl. prior charges)
prior_charge_ltv Float64 Prior/pari-passu charge contribution to LTV (drives junior-charge logic)
counterparty_type enum Drives Art. 124L counterparty RW for loan-splitting residual

Regulatory References

Topic PRA PS1/26 / CRR BCBS CRE
RE framework scope and routing Art. 124(1)–(4) CRE20.71
Six qualifying criteria Art. 124A CRE20.71–73
Underwriting standards (governance) Art. 124B
LTV definition Art. 124C CRE20.74–75
Valuation requirements Art. 124D CRE20.76
Material dependency classification Art. 124E CRE20.77
RESI loan-splitting (hard test) Art. 124F CRE20.81
RESI income-producing (soft test) Art. 124G, Table 6B CRE20.83
CRE loan-splitting Art. 124H CRE20.82
CRE income-producing Art. 124I CRE20.86
Other RE fallback Art. 124J CRE20.85
ADC Art. 124K CRE20.84
Counterparty RW for residual Art. 124L CRE20.81–82
Legacy CRR residential CRR Art. 125 (omitted from Basel 3.1)
Legacy CRR commercial CRR Art. 126 (omitted from Basel 3.1)

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