36. Where the relevant loss data to assess the impact of the downturn period under consideration is not available and it is also not possible to calibrate downturn LGD for the considered downturn period in accordance with Section 6 of these guidelines, institutions should quantify downturn LGD through any other approach subject to the following conditions:

(a) they should ensure that the appropriate MoC required to be applied in accordance with Section 4.4.3 of the [EBA GL on PD and LGD estimation] includes a Category A MoC that is strictly positive to account for the missing data;

(b) they should ensure that the resulting downturn LGD estimates including the final MoC as set out in paragraph 45 of the [EBA GL on PD and LGD estimation], for the considered downturn period are higher or equal to the minimum between

• the according long-run average LGDs plus an add-on of 15 percentage points and

• 105%;