Under 423(6) of Regulation (EU) No 575/2013 (CRR) should the deposits received as collateral be calculated as net posted collateral in order to treat posted and held cash collateral symmetrically? What if more cash collateral is posted than held? Thus should all other posted level 1 collateral not be reported?

Deposits received as collateral should be reported in the EBA template.

According to Article 423(6) of Regulation (EU) No 575/2013 (CRR) and Article 30(7) of Delegated Regulation (EU) 2015/61, deposits received as collateral shall not be considered liabilities for the purposes of Article 422, and consequently should not be reported as deposits in section 1.2 1.1 in template C 52 73.00 Liquidity coverage outflow. However the amount of cash received exceeding the amount of cash received as collateral shall be treated as deposits.

As with any other collateral, deposits received as collateral should be considered as liquid assets in accordance with Article 416 defined in Title II of the Delegated Regulation (EU) 2015/61, if the general and operational requirements for liquid assets are met, and reported in C 51 72.00, where applicable.

In line with Articles 21, 30(4) and 32(5) of Delegated Regulation (EU) 2015/61 425(3) of the CRR, if they qualify as liquid assets according to Article 416, deposits received as collateral that covers receivables from contracts listed in Annex II of the CRR and from credit derivatives that have to be returned to the counterparty within 30 days and deposits posted as collateral that qualify as liquid assets that are expected to be returned to the institution within 30 days should be netted against the cash inflow and cash outflow arising from these contracts, and be captured in row 960 240 of C 53 74.00, if the net amount is an inflow, or in row 340 of C 73.00, if the net amount is an outflow.

In respect of deposits posted as collateral, the treatment is no different from that of other collateral posted that covers payables from the contracts listed in Annex II of the CRR. If it qualifies as liquid assets according to Article 416 of the CRR, and if it is expected to be returned to the institution within 30 days, pursuant to Article 422(6), such deposits should be netted against the cash outflow arising from these contracts captured in row 1080 of C 52.00.

Notwithstanding the netting treatment within the meaning of Article 425(3) of the CRR (deposits received as collateral to be returned with the cash inflow) and the netting treatment within the meaning of Article 422(6) (deposits posted as collateral to be received with the cash outflow), the CRR does on derivatives the CRR or the Delegated Regulation (EU) 2015/61 does not allow for a general netting of deposits received as collateral with deposits posted as collateral. Consequently, the comparison made in the question (i.e. between collateral posted and held) is not relevant.

This answer is without prejudice to the delegated act on the liquidity coverage requirement.

Update 26.03.2021: This Q&A has been updated in the light of the changes introduced to Commission Delegated Regulation (EU) No 2015/61.