Question ID:
2015_1901
Legal Act:
Regulation (EU) No 575/2013 (CRR)
Topic:
Supervisory reporting - Liquidity (LCR, NSFR, AMM)
Article:
415
Paragraph:
3
Subparagraph:
b
COM Delegated or Implementing Acts/RTS/ITS/GLs/Recommendations:
Draft ITS on Supervisory Reporting of Institutions
Article/Paragraph:
Annex III templates 68, 69 and 70
Disclose name of institution / entity:
No
Type of submitter:
Competent authority
Subject Matter:
How the various types of sight deposit are to be treated in ALMM templates C68.00, C69.00 & C70.00, and whether it is possible to achieve a consistent treatment given the differences in requirements across these templates.
Question:

How are the three types of sight deposit (current accounts, instant access savings and term-less cash ISAs) to be treated in templates C68.00, C69.00 & C70.00?

Background on the question:

There are three templates where there is potential ambiguity around the inclusion or treatment of products that could be considered “sight deposits”: C68.00 – Instant access savings and term-less cash ISAs could potentially be reported in r020 “Sight deposits” or in r090 “Savings accounts without a notice period for withdrawal greater than 30 days”. C69.00 – Personal and business current accounts have no maturity term and cannot be priced in the same way as a true term product therefore could be legitimately excluded from the template; the same is true of instant access savings and term-less cash ISAs, although these could also be reported as overnight maturity from a prudence point of view. C70.00 – As personal and business current accounts have no maturity term the total funding profile calculated including them would be distorted. As per C69.00 instant access savings and term-less cash ISAs also lack terms but could be reported as overnight maturity from a prudence point of view.

Date of submission:
17/03/2015
Published as Final Q&A:
18/12/2015
Final Answer:

The reporting of sight deposits in the templates C 68.00, C 69.00 and C 70.00 of Annex XX of final draft implementing technical standard (ITS) on additional liquidity monitoring metrics under Article 415(3)(b) of Regulation (EU) No 575/2013 (EBA/ITS/2013/11/rev1 (of 24 July 2014)) is as follows:

 

In template C 68.00, provided that the deposits are placed by retail customers as defined by Article 3(8) Delegated Regulation No 2015/61:

 

- row 020 shall include all cash deposits that can be immediately withdrawn without notice;

- rows 030, 050 and 060 shall include cash deposits with a fixed term where the maturity should be identified by way of the earliest possible withdrawal date which is contractually allowed;

- rows 080 and 090 shall include deposits where the withdrawal is subject to a notice period according to the respective definitions.

 

In template C 69.00, provided that the deposits are placed by retail customers as defined by Article 3(8) Delegated Regulation No 2015/61:

- sight deposits should be assumed to mature overnight, therefore the related volume and spreads should be reported in the “overnight bucket” (columns 010 and 020);

- data on term deposits should be included in the time bands according to their original maturity;

- data on deposits with a notice period should be reported in the time buckets corresponding to the first possible date of withdrawal.

 

For template C 70.00, provided that the deposits are placed by retail customers as defined by Art. 3(8) Delegated Regulation No 2015/61, the explanation for template C 69.00 applies.

 

DISCLAIMER:

The present Q&A on Supervisory reporting is provisional. It will be reviewed after the Implementing Regulation is in force and published in the Official Journal, which may differ from the text of the draft ITS to which this Q&A relates.

Status:
Final Q&A
Answer prepared by:
Answer prepared by the EBA.
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