Question ID
2022_6352
Legal act
Regulation (EU) No 575/2013 (CRR)
Topic
Supervisory reporting - FINREP (incl. FB&NPE)
Article
99
COM Delegated or Implementing Acts/RTS/ITS/GLs/Recommendations
Regulation (EU) No 680/2014 - ITS on supervisory reporting of institutions (repealed)
Article/Paragraph
Annex V
Type of submitter
Credit institution
Subject matter
Complusory reserves in F 01.01
Question

In one of countries where we operate, Compulsory (Minimum; Obligatory) reserves are split in to non-restricted (daily due) and restricted (up to one month => “The maintenance period begins on the second Wednesday of a month and lasts to the day preceding the second Wednesday of the following month”).

Shall we present them together in a Template F 01.01 row 0030 column 0010 => "Cash balances at central banks", or restricted part should be presented as Loans and Advances (for example as Loans and Advances at amortised cost => Template F 01.01 row 0183 column 0010)?

Background on the question

Based on Q&A 2970: “Compulsory reserves at central banks shall be reported in row 010 ‘On demand [call] and short notice [current account]’ of template F 05.00 of Annexes III and IV to Regulation (EU) No 680/2014 (ITS on Supervisory Reporting).”

Based on Q&A 1057: “'Demand deposits at credit institutions’ are loans and advances in accordance with the ECB BSI Regulation that shall be reported outside the accounting portfolios, into the row 040 of template F 01.01 (see also Q&A 2013_180 and 2013_235 in this regard). On the other hand, demand deposits at counterparties other than central banks and credit institutions shall always be reported as loans and advances into the accounting portfolios. Therefore, validation rule v1251_m holds. The instructions in Annex V to the ITS on reporting (v3.0) have been amended to clarify this point. (v1251_m: {F 01.01, r0040, c0010} = {F 05.01, r0010, c0030})";

If On demand [call] and short notice [current account] to Credit Institutions are considered as Demand deposit (including also Overnight deposit - Q&A 235), shall also On demand [call] and short notice [current account] to Central Banks be considered as Demand deposit (F 01.01 row 0030 column 0010), no matter are they restricted or not?

Submission date
Rejected publishing date
Rationale for rejection

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Status
Rejected question