[1.] The statement in the Q03 is connected to the treatment of an off-balance sheet commitment after a drawdown and therefore we would prefer to have end of month spreads. Off-balance sheet items usually need a specific treatment and methodology used for on-balance sheet items cannot be directly mapped to the off-balance sheet item, due to its diverse nature. What can be also proven by their suggested treatment within template C 69.00, where both volume and spread should be determined on the day on which the highest amount of the period is drawn. In the light of the above explanations, we would suggest calculation end of month spreads for off-balance sheet commitments within template C 69.00.
[2.] We have major concerns related to the Q04 which proposes a focus only on those sight deposits that are new for applicable reporting period. If this means that we should include only ‘pure’ new clients then this imposes also some technical and logical issues. E.g. we have a client for some time, then this client goes to another bank for few months and comes back. Is this client really a ‘pure’ new one? This is just one example about client’s movements. Thus we would suggest to stick with the treatment of that items as they have been rolled-over, instead of reporting the sight deposits where the depositor did not have a sight deposit in the preceding reporting period.