The document presents a model for estimating exposure at default (EAD) for contingent credit lines (CCLs) at the portfolio level. It models each CCL as a portfolio of put options, with the exercise of each put following a Poisson process. The model convolutes the usage distributions of individual obligors, sub-segments, and segments to estimate the portfolio-level EAD distribution. The authors test the model using data from Moody's and find near-Gaussian results. They discuss future work to refine the model and make it more practical for banks to estimate regulatory capital requirements.