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  3. 2022_6415 Upcoming deals in Liquiity risk reporting
Question ID
2022_6415
Legal act
Regulation (EU) No 575/2013 (CRR)
Topic
Liquidity risk
Article
Article 32
Paragraph
1
COM Delegated or Implementing Acts/RTS/ITS/GLs/Recommendations
Delegated Regulation (EU) 2015/61 - DR with regard to liquidity coverage requirement
Article/Paragraph
32(1) but not only
Type of submitter
Credit institution
Subject matter
Upcoming deals in Liquiity risk reporting
Question

Our institution currently reports the LCR including only deals wth value date prior or equal to the reporting date. We would like to include cashflows from contractual upcoming deals, from their trade date and before the actual value date.

To raise funding, the bank issues debt securities and makes money market borrowing. As these deals are contractual, between the trade date and the value date we expect an inflow for the cash to be received as funding. Are we authorized to account these upcoming cashflows as inflows in the LCR? (between trade date and value date) And as soon as the value date occurs, the deal is booked as liabilities and it would become an outflow.

The bank  makes money market lending. To be fair with the above approach, as these deals are contractual, between the trade date and the value date we expect an outflow for the cash to be delivered as a loan. Shall we  account these upcoming cashflows as outflows in the LCR? (between trade date and value date) And as soon as the value date occurs, the deal is booked as asset and it would become an inflow.

If the above approach is approved by EBA, are we authorized to apply it only for Money market deals and issued securities? or shall we apply it for all deals?

Our last concern is about the other reporting: If we apply this approach, shall we apply it as well to C66, NSFR? As it would make a deviation from the balance sheet in value date and especially the FINREP. Would it lead to EBA validation rules issues between the different reporting?

Thank you,

 

Background on the question

Our institution currently reports the LCR including only deals wth value date prior or equal to the reporting date. We would like to include cashflows from contractual upcoming deals, from their trade date and before the actual value date.

Submission date
30/03/2022
Rejected publishing date
26/07/2022
Rationale for rejection

This question has been rejected because it does not fulfil the formal criteria for submission. 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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