Please could you clarify the definition of facilities offered to non-financial corporates to be reported in rows 1230 and 1240 of template 52?

Could you confirm our understanding that general working capital facilities provided to non-financial corporate entities (e.g. revolving credit facilities in place for general corporate or working capital purposes) should not be classified as “facilities provided for the purpose of replacing funding of the client in situations where he is unable to obtain its funding requirements in the financial markets”, but as credit facilities and therefore reported in row 1230. The instructions and Article 424.3(c) specifically excludes facilities “provided for the purpose of replacing funding of the client in situations where he is unable to obtain its funding requirements in the financial markets” from rows 1230-1240. We understand this definition to cover liquidity facilities which would imply a 0 entry for row 1240 and for all non-financial corporate liquidity facilities to be reported in row 1320. Please could you confirm whether this reading is correct or provide an alternative definition of the requirements for row 1240.

Regulation (EU) No 575/2013 (CRR) does not provide an explicit definition of committed liquidity and credit facilities for liquidity purposes.

For reporting purposes:

• General working capital facilities which fulfill all the conditions under Art. 424(3) of the CRR (e.g. they have been granted to customers that do not qualify for the retail exposure class under the Standardised or IRB approach; they have been provided to clients that are not financial customers; they have not been provided for the purpose of replacing funding in situations where the client is unable to obtain its funding requirements in the financial markets) shall be reported in row 1230 of C 52.00 'undrawn committed credit facilities';

• If the facility does not fulfill the requirements under Art. 424(3) and has not been granted to a retail customer, it shall be reported in row 1320 of C 52.00.

This answer is without prejudice to further guidance which may be provided in the context of the delegated act on the liquidity coverage ratio. Treatment of credit and liquidity facilities might be reconsidered accordingly.

See also questions 2013_506 and 2013_563.