2018_3689 ALMM - C 70.00 : Reporting on holidays and weekends of internationally active credit institutions with subsidiaries in different countries in ‘Roll-over of funding' template

Question ID:: 2018_3689
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Acts/RTS/ITS/GLs/Recommendations:: Regulation (EU) No 680/2014 - ITS on supervisory reporting of institutions (repealed)
Article/Paragraph:: Annex XIX, part 1.5, paragraph 12
Disclose name of institution / entity:: No
Type of submitter:: Credit institution
Subject Matter:: ALMM - C 70.00 : Reporting on holidays and weekends of internationally active credit institutions with subsidiaries in different countries in ‘Roll-over of funding' template
Question:: How should (banking) holidays and weekends be reflected in C 70.00 (zeros, empty lines or constant volumes)? How should an internationally active credit institution with subsidiaries in different countries reflect holidays in different countries and working days in the weekend? Is there a different approach to be taken for non-maturity funding versus term funding in light of weekends and (banking) holidays?
Background on the question:: Referring to Annex XIX -INSTRUCTIONS FOR COMPLETING THE ADDITIONAL MONITORING TOOLS TEMPLATE OF ANNEX XVIII, it is stated in part 1.5 in paragraph 12 that “For months with less than 31 days as well as for weekends, irrelevant lines shall be left empty”. According to the instructions lines referring to weekends in that reporting period should be empty. Does this mean these cells do not contain any values (thus not reporting zeros or any other figures)? How should (banking) holidays be reflected in general in C 70.00? In our opinion the following options are possible: • We consider as the credit institution as not having any business (thus reporting zeros) • We consider as the credit institution as not operational (thus reporting no values and leaving the resp. lines empty) • We consider constant volumes (thus reporting the same values as the previous business day) How should an internationally active credit institution with subsidiaries in different countries, reflect holidays in different countries (e.g. HQ in France is operational; Subsidiary in Czech Republic has a holiday)? Furthermore, in certain countries (e.g. Hungary), credit institutions operate in the weekend (on Saturdays), how should this be reflected in the template as this conflicts with the instructions (where it is stated to leave those lines empty)? Is there a different approach to be taken for non-maturity funding versus term funding wrt the new funding/roll-over/matured amount in light of weekends and (banking) holidays?How should deposits be reported which mature during weekends or (banking) holidays? How should transactions (e.g. payments with debit/credit cards) in the weekend and on banking holidays be reflected in the template?
Date of submission:: 31/01/2018
Published as Final Q&A:: 13/12/2019
Final Answer:: According to Annex XIX under section 1.5 paragraph 12, for months with less than 31 days as well as for weekends, irrelevant lines in C 70.00 shall be left empty, as in such
days institutions are non-operational (or they do not exist in case of months with less than 31 days). Accordingly, holidays and – more in general – non-operational days
should follow the same approach.
With regard to internationally active banking groups, items in the template shall be left empty as long as all credit institutions within the group are non-operational ,
meaning that where even only one subsidiary is operational in a given day, relevant items in the template must be completed.
According to Annex XIX, non-maturity and term funding should follow the same approach in irrelevant lines of C 70.00 since no difference is envisaged in reporting
instructions in this regard.
Status:: Final Q&A
Answer prepared by:: Answer prepared by the EBA.