If an institution has unsecured deposits from a central bank, are those deposits from financial customers or deposits from non-financial customers?
Article 422(5) of Regulation (EU) No 575/2013 (CRR) states, that deposits from non-financial customers that do not fulfil the criteria of paragraphs 3 and 4 should be treated with a 40% outflow rate. However there is no definition, what a non-financial customer is. It is clear, that non-financial corporations are included here and that banks and financial corporations are not included. But it is unclear if a central bank is treated like a bank (meaning it is a financial customer) or like a government (meaning it is a non-financial customer).
In the absence of a specific treatment for reporting outflows on unsecured deposits from central banks under Regulation (EU) No 575/2013 (CRR), and without prejudice to further guidance which may be issued under the Delegated Act in accordance with Article 460, the treatment applied to deposits by non-financial customers under Article 422(5) should also be applied to unsecured deposits from central banks.
Update 26.03.2021: This Q&A has been archived as the issue it deals with is explained or addressed in Article 28(1) of Delegated Regulation (EU) 2015/61.