Question ID:
Legal Act:
Regulation (EU) No 575/2013 (CRR)
Supervisory reporting - Liquidity (LCR, NSFR, AMM)
COM Delegated or Implementing Acts/RTS/ITS/GLs/Recommendations:
Regulation (EU) 2021/451 – ITS on supervisory reporting of institutions
Annex 23
Disclose name of institution / entity:
Type of submitter:
Credit institution
Subject Matter:
Withdrawable Central Bank Reserves in ALMM C 66.01 when considered Liquid Assets

Where should withdrawable Central Bank Reserves that are considered Liquid Assets according to Regulation (EU) 2015/61 be allocated in ALMM C 66.01 Maturity Ladder?

Background on the question:

According to EBA Q&A 2018_4318 Withdrawable Central Bank Reserves that are available overnight at the latest shall be reported as inflows in column 020 of item 2.2.5 (‘Monies due not reported in 2.1 resulting from loans and advances granted to central banks’).

In the amendment of Annex 23 of Regulation (EU) 2021/451 there seems to be a discrepancy with the above and the updated instructions.

In point 21 of the General Instructions it is clear that non-withdrawable reserves are not to be reported in the Maturity Ladder The non-withdrawable part of the central bank reserves shall not be reported anywhere in the template, but nothing is mentioned for withdrawable reserves in this section of the instructions.

In the instructions for item 2.2.5 where in the Q&A was stated that this item should be allocated the following is mentioned:This item shall not include withdrawable cash reserves as reported in item 3.2.

Therefore, there seems to be a discrepancy between pre-DPM3.2 Q&A and DPM 3.2 instructions, since there is not any row in the inflows section where this item can be allocated

Date of submission:
Published as Rejected Q&A
Rationale for rejection:

This question has been rejected because the issue it deals with is already explained or addressed in Regulation (EU) 2021/451 - ITS on supervisory reporting of institutions, Annex 23. Instructions for row 0740.

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Rejected question