Question ID:
2016_2598
Legal Act:
Regulation (EU) No 575/2013 (CRR)
Topic:
Supervisory reporting - Liquidity (LCR, NSFR, AMM)
Article:
428
COM Delegated or Implementing Acts/RTS/ITS/GLs/Recommendations:
Regulation (EU) No 680/2014 - ITS on supervisory reporting of institutions (repealed)
Article/Paragraph:
Annex XII, C 60.00
Disclose name of institution / entity:
No
Type of submitter:
Competent authority
Subject Matter:
Reporting of initial margin posted in the context of derivative transactions and contribution to default funds to CCPs
Question:

Where should assets which a bank has posted on its own behalf as initial margin in the context of derivative transactions and contribution to default funds to CCPs be reported in the template C 60.00?

Background on the question:

A clarification is requested on which rows of the template C 60.00 should capture the assets (securities and cash) posted by banks on its own behalf as initial margin in the context of derivatives transactions and contribution to default funds to CCPs.

Date of submission:
27/01/2016
Published as Final Q&A:
15/04/2016
Final Answer:

On balance sheet securities which a bank has posted on its own behalf as initial margin in the context of derivatives transactions and of contribution to default funds to CCPs should be reported in the different rows envisaged in template C 60.00 of Annex XII of Regulation (EU) No 680/2014 - ITS on supervisory reporting of (ITS on reporting) for encumbered securities for a period greater than 12 months depending on the category of the security posted.

Cash which a bank has posted on its own behalf as initial margin in the context of derivatives transactions and of contribution to default funds to CCPs should be reported in the different rows (within section 1.9:  rows 900 - 1250) envisaged in template C 60.00 for encumbered loans for a period greater than 12 months depending on the category of the borrower.

This encumbrance period assumes that banks are expected to keep their initial margin in the long term.

Following Q&A 2014_718 reverse repos where the collateral received has been re-hypothecated as initial margin in the context of derivatives transactions and of contribution to default funds to CCPs should not be considered encumbered and the collateral received and reused should be considered as encumbered.

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