Would a retail deposit account, which can be serviced by telephony as well as by internet, not trigger the “internet only” risk factor for high outflow classification?
Delegated Regulation (EU) 2015/61 Article 25 sets out criteria where retail deposits shall be subject to higher outflow rates. One such condition that contributes to the allocation of balances to higher outflow categories is identified in paragraph 2(b), where “the deposit is an internet only account”. We seek clarification on the definition of an “internet-only account”.
Does this relate to accounts where customer access is limited to online channels only- i.e. would accounts serviced by both online means and telephone access be excluded from the internet-only definition?
Under the Delegated Regulation (EU) 2015/61 as amended by Delegated Regulation (EU) 2018/1620, paragraph 2(b) of Article 25 has been replaced by the following: “the deposit is an internet access-only account”.
In that regard, a service by telephone should be seen as a substitute to service by internet.
This is because the relationship between the depositor and the credit institution, which is assumed to characterise the sensitivity of deposits to withdrawals during times of stress, in the case of an internet access-only account can assumed to be equal to a relationship that is characterised by exclusive access via telephone or both telephone and internet.
Consequently, a retail deposit account, which can exclusively be serviced by telephone as well as by internet, should trigger the “internet access only” risk factor for high outflow classification in accordance with Article 25(3) of Delegated Regulation (EU) 2015/61 as amended by Delegated Regulation (EU) 2018/1620.