Under Regulation (EU) 575/2013, Article 25.4 allows for the exclusion of non-maturing retail deposits from the calculation of outflows if a significant penalty is imposed for early withdrawals within 30 calendar days. These deposits should be reported in the c73 1.1.1.1 category, which refers to "deposits exempted from the calculation of outflows." We currently report their entire outstanding amount with a run off rate of 0.

However, for non-retail deposits, there is no specific article or reporting instructions provided for this type of deposit. Therefore, it is unclear how these deposits should be treated in terms of outflow calculations and reporting.

Secondly, we wonder if retail deposit with a notice period beyond the LCR horizon may be considered as “deposits exempted from the calculation of outflows” and reported on C73 1.1.1.1. And similarly what is the treatment for the same transaction with non-retail counterparty. 

Then, in the last paragraph of Article 25.4, the treatment for amortizing retail term deposits seems explained: “If a portion of the deposit referred to in the first subparagraph can be withdrawn without incurring such a penalty, only that portion shall be treated as a demand deposit and the remaining balance shall be treated as a term deposit as referred to in this paragraph” .

We understand that only the amortizing amounts of term deposits should be reported in the c73 1.1.1 section depending on the quality of the deposit. This treatment differs from a demand deposit, where the entire balance is counted as outflows.

For non retail deposit, the article 22.2(b) could indicate that only the amortizing part of non-retail deposit should be reported. But the wording is totally different.