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In February, the PRA published a consultation paper containing its proposals as to how the eligibility criteria for guarantees to be treated as unfunded credit protection under the Capital Requirements Regulation (CRR) should be interpreted (our blog is here). Those proposals have proved to be controversial. In particular the PRA: suggests that the requirement for the guarantor to be obliged, contractually, to pay out ‘in a timely manner’ means that the pay-out should be…