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Regulation (EU) No 680/2014 - ITS on supervisory reporting of institutions (repealed)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
Disclose name of institution / entity:
No
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?

Date of submission:
02/02/2022
Published as Rejected Q&A
07/11/2022
Rationale for rejection:

This question has been rejected because the issue it raises is beyond the remit of the Q&A process and as such it cannot be addressed via a Q&A. 

The Single Rule Book Q&A tool has been established to provide explanations and non-binding interpretations on questions relating to the practical application or implementation of the provisions of legislative acts referred to in Article 1(2) of the EBA’s founding Regulation, as well as associated delegated and implementing acts, and guidelines and recommendations, adopted under these legislative acts. The Q&A process cannot, for example, consider issues which would require changes to the regulatory framework.

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
Image CAPTCHA