Question ID:
Legal Act:
Regulation (EU) No 575/2013 (CRR)
Liquidity risk
411, 427
2, 1(b)
COM Delegated or Implementing Acts/RTS/ITS/GLs/Recommendations:
EBA/GL/2013/01 - Guidelines on retail deposits subject to different outflows for purposes of liquidity reporting
421(1), 421(2), 421(1) (a), 422, 422(5)
Disclose name of institution / entity:
Name of institution / submitter:
Coop Bank
Country of incorporation / residence:
Type of submitter:
Credit institution
Subject Matter:
Treatment of "E-money" in Liquidity Reporting

We seek clarification on how the issue of “e-money” is to be treated in the computation of liquidity requirements and reporting; “LCR, stable funding reporting and ALMM”.

From a liquidity related context, would the issued “e-money” be accounted for/treated according to “Article 421(1)” of CRR under retail deposits? And therefore, be included in the computation of demand deposits, where the outflow is stressed with 5% according to “Article 421(1) (a)? Or stressed with 10% following “Article 421(2), in relation to whether a customer has an established relationship with the bank and is covered by the “Deposit Guarantee Scheme”?

Alternatively, would the issued “e-money”, from a liquidity related perspective be accounted for under “Other Liabilities” according to “Article 422 of CRR? Hence, entail the computation of “Other Liabilities” as per “Article 422(5), where outflows are stressed with 40% and 20% respectively? Depending on whether the commitment/liability is covered by the “Deposit Guarantee Scheme”?

Background on the question:

Our bank will begin issuing “e-money”, with the intent of having it used for purchases in Coop’s stores. Customers will initially purchase the “e-money”, transferring funds to the bank. The “e-money” will then be held on an account in the bank, with an on demand accessibility via the electronic wallet for purchases in the bank's stores. We would like to know how this issue is to be treated in the computation of LCR, Stable Funding and ALMM.

Date of submission:
Published as Final Q&A:
Final Answer:

Electronic money and funds received in exchange for electronic money should not, in accordance with Directive 2009/110/EC (The E-Money Directive, recital 13), be considered as a deposit taking activity for the purposes of the definition of credit institutions and therefore will not fall within the scope of a Deposit Guarantee Scheme (Recital 29 Directive 2014/49/EU on Deposit Guarantee Schemes).

For the purposes of the LCR, electronic money issued should be treated as liabilities to the respective clients (retail, non-financial customer etc.) and their corresponding outflows in accordance with Article 22 of the Commission Delegated Regulation (EU) 2015/61.

In particular, as per Article 411(2) of Regulation (EU) No 575/2013 (CRR) 3 of the Commission Delegated Regulation (EU) 2015/61, liabilities to a natural person or to an SME, under the conditions set out therein in its paragraph 8, should follow the treatment of ‘other retail deposits’, for the purposes Article 25 of the LCR.

Article 427(1)(b)
for the purpose of reporting items providing stable funding, and, 428m and 428n CRR for the purposes of the calculation of the net stable funding ratio (NSFR)reporting items providing stable funding considers as retail deposits those which are treated as such in the LCR. The same approach is followed in the instructions of the templates reporting on Additional Liquidity Monitoring Metrics (Commission Implementing Regulation (EU) 20167/3132114). 

Final Q&A
Answer prepared by:
Answer prepared by the EBA.
Note to Q&A:

Update 26.03.2021: This Q&A has been updated in the light of the changes introduced to Regulation (EU) No 575/2013 (CRR).