How to determine the residual maturity of the encumbrance in a cover pool if it derives from covered bonds with different maturity?
In our jurisdiction the covered bonds have a pool concept. All assets in the pool provide collateral to all the covered bonds. We found no rule how to determine the residual maturity of the encumbrance if it derives from covered bonds with different maturity. Many of our banks include government bonds in cover pool. When the remaining maturity of their covered bonds fall below one year, providing only 50% of available stable funding, but the government bonds will require 85% stable funding, assuming all the asset encumbrance remains over one year aligning with the longest tranche.
For the purpose of determining the relevant required stable funding factor to the assets encumbered in a cover pool funded by covered bonds, similarly to the assumption foreseen in point (a) of Article 428p(6) of Regulation (EU) No 575/2013 (CRR) to define the order of encumbrance of assets included in a pool, institutions should assume that assets in the cover pool are encumbered in order of increasing liquidity on the basis of the liquidity classification pursuant to the delegated act referred to in Article 460(1), starting with assets ineligible for the liquidity buffer.
This means that the residual maturity of encumbrance of the most liquid assets should be considered, for these proposes, corresponding to the shortest residual maturity of covered bonds. The treatment here described should apply without prejudice of the consideration of the full cover pool as global guarantee for all the covered bonds as laid down in the national law of the Member States transposing the covered bonds Directive (Directive (EU) 2019/2162).