Counting of days past due

2.1 For the purpose of Article 178(1)(b) of the Credit Risk: Internal Ratings Based Approach (CRR) Part, where any amount of principal, interest, or fee has not been paid at the date it was due, firms should recognise this as the credit obligation being past due. Where there are modifications of the schedule of credit obligations, as referred to in Article 178(2)(e) of the Credit Risk: Internal Ratings Based Approach (CRR) Part, the firm’s policies should clarify that the counting of days past due should be based on the modified schedule of payments.

2.2 Where a credit arrangement explicitly allows the obligor to change the schedule, suspend, or postpone the payments under certain conditions, and the obligor acts within the rights granted in the contract, the changed, suspended, or postponed instalments should not be considered past due, but the counting of days past due should be based on the new schedule once it is specified. Nevertheless, if the obligor changes the schedule, suspends, or postpones the payments, the firm should analyse the reasons for such a change and assess possible indications of unlikeliness to pay, in accordance with Articles 178(1) and 178(3) of the Credit Risk: Internal Ratings Based Approach (CRR) Part and Chapter 3 – Indications of unlikeliness to pay of this SS.