Question ID
2022_6413
Legal act
Regulation (EU) No 575/2013 (CRR)
Topic
Liquidity risk
Article
28
COM Delegated or Implementing Acts/RTS/ITS/GLs/Recommendations
Not applicable
Article/Paragraph
COMMISSION DELEGATED REGULATION (EU) 2015/61 Article 28 and 31
Type of submitter
Other
Subject matter
Article 28 Outflows from other liabilities
Question

Credit institution is not traditional credit institution - institution offers only loans and deposits. Client's have under their name Current account, but client's cannot operate those accounts. Client's can make payments to those accounts from other credit institutions and those accounts are used to pay out loans to client's account in other credit institutions. Does such current accounts should be reported for LCR calculation?

Background on the question

Those current accounts usually have some outstanding amounts on reporting reference date, but they usually are premature payments made from client to cover loans, but money has not yet transferred from current account to loan account.

For example: client has current account and loan account. Remaining sum of the loan is 10 000 euros. On reporting reference date 31.03.22, client made payment to current account in amount of 10 000 euros and outstanding amount is now 10 000 euros. In April, this amount will be considered to cover loan. So, on the reference date 31.03.22, does this amount on current account (10 000 euros) should be considered in LCR reporting?

Another exmple is: client has prematurely ended his/her loan and has paid more than needed. So, at the reporting reference date, there is a small amount on current account (20 euros). Client has to compose an application for transferring the money from current account to antoher credit institution's current account client has. Does this amount should be considered in LCR reporting?

Submission date
Rejected publishing date
Rationale for rejection

This question has been rejected because the question is not sufficiently clear.

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Status
Rejected question