A bank holds US$3bn of assets it could sell within days at little loss. In a severe stress, it estimates US$2.4bn of its funding would leave within 30 days.
Credit Conversion Factor: a Worked Example
An unused limit is a promise to lend, and a promise uses capital.
BY MICHAEL SHANG · SIXTEEN YEARS IN COMMERCIAL BANKING · UPDATED
// THE SHORT ANSWER
A credit conversion factor answers the question a borrower asks when the bank charges for a limit nobody has used: why does an empty line cost anything? Because the bank has promised to lend, and a borrower heading for trouble draws what it was promised. The factor is the share of each promise that the capital rules count as if it were already lent. A committed revolver, a performance bond and a trade letter of credit each carry their own factor, and the converted amount is then risk-weighted like a loan. Which factor applies depends on the market and on the bank's approach to capital.
BASIS Practitioner judgment from sixteen years in commercial banking, set out in How Bankers Think (Highbank Press, 2026). Every borrower on this site is a composite constructed for teaching, not a client. The market is mid-market commercial lending as practised in New Zealand and Australia; where a convention differs elsewhere, the page says so.
// MAKE THE CALL
Issue 09 — The Tuesday List. Eight dashboards. Two intensive-care slots. Portfolio triage, Tuesday 8:30am. Your call first, then the senior banker's.
// 01 — WHY AN UNDRAWN LIMIT USES CAPITAL
A balance sheet shows what a bank has lent. It does not show what the bank has promised to lend, or the guarantees it has given on a customer's behalf, and both can become loans at the worst moment. A business that is losing money draws its revolver to pay suppliers. A customer whose contract goes wrong has its performance bond called, and the bank pays the beneficiary and looks to the customer for reimbursement. Capital rules therefore count part of each promise as exposure today.
The factor deals with how much of the promise is likely to be called on. The risk weight deals with how likely the borrower is to fail. They answer different questions and are applied one after the other.
// 02 — HOW THE FACTORS ARE SET
On the standardised approach each item falls into a category with a fixed percentage. The Basel framework's current table runs from 100% for direct credit substitutes, such as a guarantee of a customer's borrowing or a standby letter of credit that backs a financial debt, through 50% for transaction-related items such as performance and bid bonds, 40% for commitments of any maturity, 20% for short-term self-liquidating trade letters of credit, down to 10% for a commitment the bank can cancel at any time without notice. Where the bank has committed to issue an off-balance-sheet item, such as a line for future letters of credit, the lower of the two factors applies.
The markets do not use one table. Australia's APS 112 follows the Basel factors but has no 10% line: an arrangement the bank can cancel is still a commitment at 40% unless it meets every condition in Attachment C, among them that the borrower is a closely monitored corporate, no fees are charged and each drawing is assessed before it is made, in which case it is not a commitment at all. The UK, until 31 December 2026, uses four buckets of 100%, 50%, 20% and 0%, which grade committed lines by original maturity and give a cancellable line nothing; from 1 January 2027 its Basel 3.1 rules move most commitments to 40% whatever their term and cancellable lines to 10%, and keep performance bonds and documentary credits at 20%. New Zealand's Reserve Bank sets its own table for banks on the standardised approach, so the Basel figures should not be read as New Zealand's.
Where their supervisor allows it, banks approved to use advanced internal models estimate their own factors for some facilities, mostly revolving ones, from how much borrowers drew before they defaulted, subject to floors.
// 03 — THE EXAMPLE
A builder of truck bodies, constructed for this page like every figure in it, has a three-year committed revolver of US$12m with US$5m drawn, US$1.5m of performance bonds issued to fleet customers, US$2m of import letters of credit for chassis secured on the shipments, a US$0.8m standby letter of credit backing an equipment loan from a finance company, and a US$1m overdraft, unused, that the bank can cancel at any time without notice. Amounts in US$m.
The UK column uses today's buckets: 50% on a revolver of more than a year, 20% on bonds and on letters of credit secured on the goods, nothing on the cancellable overdraft. The Australian column assumes the overdraft does not meet every Attachment C condition. The totals sit close together, but for different reasons, and the revolver is the largest single source of exposure in every column. On the UK's 2027 rules the same facilities would come to 9.40: the revolver falls to 40%, the overdraft rises to 10% and the bonds stay at 20%.
Apply a 100% risk weight and a 12% capital ratio, both the example's assumptions rather than any bank's figures, and the Basel column needs about US$1.18m of capital, of which about US$0.34m supports the unused part of the revolver. If the builder asks to lift the revolver to US$16m for comfort, without drawing more, the extra US$4m adds US$1.6m of exposure and about US$0.19m of capital.
// 04 — HOW IT DIFFERS FROM EXPOSURE AT DEFAULT
The factor is an input; exposure at default is the result. Exposure at default adds the converted share of everything undrawn or contingent to the drawn balance, and the factor is the percentage used for that conversion. In the Basel and Australian columns the revolver's factor is 40% and its exposure at default is US$7.8m; on the UK's current buckets the factor is 50% and the exposure US$8.5m.
It is also distinct from utilisation, which is how much of a limit is drawn today. Utilisation describes the customer's current behaviour; the factor is the rule, or the model, for what that behaviour becomes before a default. A revolver used at 10% for years can still be drawn to the limit in the month before a business fails, which is why the factor does not fall because a customer has been careful.
DEFINED IN ONE PARAGRAPH → · RISK-WEIGHTED ASSETS, WORKED → · EXPECTED LOSS, WORKED →
// 05 — WHERE IT DECIDES A FILE
The factor sits behind three things a borrower sees. The first is the utilisation fee and the line or commitment fee: an undrawn committed limit uses capital, so the bank prices it, and a borrower who asks for headroom it will not draw is asking the bank to hold capital for comfort. The second is structure. An uncommitted facility the bank can cancel takes a lower factor in some markets, and the UK's change in 2027 ends the lighter treatment of committed lines of a year or less. The third is the annual review, where a credit officer cancels limits that sit unused or asks for cash cover over a bond line.
The factor also feeds a bank's tests of concentration. The Basel large exposures standard counts off-balance-sheet items through the same factors, with a floor of 10%, so a group whose drawn debt looks modest can still approach a bank's limits once its bonds and undrawn lines are added.
HOW BANKS PRICE BUSINESS LOANS → · BANK GUARANTEE OR LETTER OF CREDIT → · CONNECTED EXPOSURE →
// SOURCES
The documents the statements on this page rest on. Each was opened and checked when cited.
- Basel Committee on Banking Supervision, Basel Framework, CRE20 Standardised approach: individual exposures — paragraphs CRE20.94 to CRE20.101 — Sets the standardised CCFs of 100%, 50%, 40%, 20% and 10% by type of off-balance-sheet item, and the rule that the lower of two applicable factors is used — sections 02 and 03.
- Australian Prudential Regulation Authority, Prudential Standard APS 112 Capital Adequacy: Standardised Approach to Credit Risk (compilation registered June 2025) — Attachment C and Table 17 — Defines commitments to include arrangements the ADI can cancel unconditionally, sets the conditions for exclusion, and lists the CCFs used in the Australian column — sections 02 and 03.
- UK Capital Requirements Regulation (EU) No 575/2013 as retained, Article 111(1) and Annex I — Classifies off-balance-sheet items as full, medium, medium/low and low risk and, through Article 111, applies 100%, 50%, 20% and 0% — the UK column in section 03.
// QUESTIONS PEOPLE ASK
- What is the credit conversion factor for an undrawn commitment?
- Under the current Basel standardised table it is 40% for a commitment of any maturity, and 10% for one the bank can cancel at any time without notice. Australia uses 40% and has no 10% line, though a facility meeting strict conditions falls outside the definition of a commitment. The UK uses 50% for committed lines over a year, 20% for a year or less and 0% for cancellable lines until 31 December 2026, then 40% and 10%. Banks using their own models may estimate a different figure.
- Why do banks charge a fee on an undrawn facility?
- Because a committed limit is a promise the bank must keep, and the capital rules count part of it as lent from the day it is signed. The bank holds capital and liquidity against that promise whether or not the customer draws, and the commitment or line fee pays for them. A limit the bank can cancel at any time carries a lower factor under the Basel table and in the UK, though in Australia only if it meets strict conditions, which is one reason uncommitted overdrafts often cost less to keep open.
- What is the difference between a CCF and EAD?
- Exposure at default is a total; the credit conversion factor is a rate used to build it, saying what share of each undrawn or contingent amount is added to the drawn balance. For a US$20m revolver with US$8m drawn and a 40% factor, exposure at default is US$8m plus 40% of US$12m, or US$12.8m. The factor is the assumption; the exposure is the result.
- What conversion factor applies to a bank guarantee or letter of credit?
- It depends on what the instrument does. A guarantee of a customer's borrowing, or a standby letter of credit backing a financial debt, is a credit substitute and takes 100% in the Basel and Australian tables. A performance or bid bond takes 50% under Basel and Australian rules, and 20% in the UK, both now and under its 2027 rules. A short-term letter of credit for imported goods, secured on the shipment, takes 20% in all three tables.
THE IN-TRAY · ONE MINUTE
Make the call on one file.
A short file on the ground this page covers. Every option opens with how far it sits from a senior banker’s read.
1 FILES · PICK A CALL ON ANY OF THEM
3 MORE ON THE BANK · FUNDING AND LIQUIDITY →WHERE DO YOU READ FROM? THE PLACEMENT →
// SUBSCRIBE
The Lab.
One case file and one question, in your inbox every Tuesday morning, New Zealand time. The senior banker's read opens only after you answer.
FREE WITH IT · ANNOTATED PDF
A complete credit paper on a published file, with the approver's notes on what each section has to answer.
No spam. Unsubscribe anytime. Educational content only.
