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
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.

Submission date
Rejected publishing date
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