Should committed facilities (Annex XII, C 80.00, r1060), the residual contractual maturity of which is equal or longer than six months, but which can be drawn down at any time regardless of their (residual) contractual maturity, be reported in column 0010?

The provisions of Article 428q(1) of Regulation (EU) No 575/2013 as amended by Regulation (EU) 2019/876 (CRR2) stipulate:

“1. Unless otherwise specified in this Chapter, institutions shall take into account the residual contractual maturity of their assets and off- balance-sheet transactions when determining the required stable funding factors to be applied to their assets and off-balance-sheet items under Section 2.”

However, it is important to note that the undrawn portion of committed credit and liquidity facilities pursuant to the delegated act referred to in Article 460(1) CRR shall be subject to a 5% required stable funding factor, irrespective of their residual contractual maturity, in accordance with Article 428s(1), point (c), of the CRR2.

Furthermore, it should be noted that EBA Q&A (ID) 2015_1994 clarifies that “All undrawn committed credit facilities that qualify as 'medium risk' or 'medium/low risk' under Annex I of Regulation (EU) No 575/2013 as amended by Regulation (EU) 2019/876 (CRR2) shall be reported in row 1320, column 110 (within three months) of template C 60.00 of Annex XII to Regulation (EU) No 680/2014 (ITS on Supervisory Reporting) as amended, since they can be drawn down at any time regardless of their contractual maturity."

Although this EBA Q&A refers to former NSFR templates that did provide for separately reporting undrawn committed credit facilities that qualify as ‘medium risk’ or ‘medium/low risk’ under Annex I, in accordance with Article 428.1 sub (k) CRR2, the same rationale may in fact apply for all committed facilities (to be reported in Annex XII, C80.00, r1060) that can be drawn down by the counterparty at any time regardless of their (residual) contractual maturity.

Therefore, the question arises if committed facilities (Annex XII, C80.00, r1060) for which the residual contractual maturity is equal or longer than six months, but which can be drawn down at any time regardless of their (residual) contractual maturity, should be reported in column 0010 (instead to determine the correct bucket (columns 0010-0030) for committed facilities (Annex XII, C 80.00, r1060), including for committed facilities which can be drawn down at any time regardless of their (residual) contractual maturity, as may be implied by the provisions of Article 428q(1) of the CRR2?