Question ID:
2021_6209
Legal Act:
Regulation (EU) No 575/2013 (CRR)
Topic:
Liquidity risk
Article:
428ab
COM Delegated or Implementing Acts/RTS/ITS/GLs/Recommendations:
Not applicable
Article/Paragraph:
Not applicable
Disclose name of institution / entity:
Yes
Name of institution / submitter:
Bulgarian National Bank
Country of incorporation / residence:
Bulgaria
Type of submitter:
Competent authority
Subject Matter:
SF factors
Question:

We found possible inconsistency in CRR texts related to required stable funding for level 2B securitisations notably articles 428z and 428ab

Background on the question:

We found possible inconsistency in CRR texts related to required stable funding for level 2B securitisations. See below:

 

Article 428z

25 % required stable funding factor

Unencumbered level 2B securitisations pursuant to the delegated act referred to in Article 460(1) shall be subject to a 25 % required stable funding factor, regardless of whether they comply with the operational requirements and with the requirements on the composition of the liquidity buffer as set out in that delegated act.

 

Article 428ab

35 % required stable funding factor

The following assets shall be subject to a 35 % required stable funding factor:

(a) unencumbered level 2B securitisations pursuant to the delegated act referred to in Article 460(1), regardless of whether they comply with the operational requirements and with the requirements on the composition of the liquidity buffer as set out in that delegated act.

(b) …

 

Obviously the text in bold refers to exactly the same positions that have to receive different stable funding factors which is legally not feasible.

Date of submission:
15/09/2021
Published as Rejected Q&A
22/02/2022
Rationale for rejection:

This question has been rejected because the issue it deals with is already explained or addressed in Articles 428ab and 428z of Regulation (EU) No 575/2013 (CRR). 

For further information on the purpose of this tool and on how to submit questions, please see “Additional background and guidance for asking questions

Status:
Rejected question
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