Question ID
2023_6686
Legal act
Regulation (EU) No 575/2013 (CRR)
Topic
Supervisory reporting - Liquidity (LCR, NSFR, AMM)
Article
460
COM Delegated or Implementing Acts/RTS/ITS/GLs/Recommendations
Delegated Regulation (EU) 2015/61 - DR with regard to liquidity coverage requirement
Article/Paragraph
25(2)(b)
Type of submitter
Other
Subject matter
Other retail deposits subject to higher outflow rates
Question

Do the retail customers of financial institutions like challenger banks or fintechs whose clients specifically use mobile apps to sign up, log in, top up, use the features like payments, open savings accounts, invest, and etc comply with “an internet-access only account” definition? Is there a difference between customers who hold virtual cards and cannot access their funds via ATMs and the ones that have physical cards and can do so?

Background on the question

Under Delegated Regulation (EU) 2018/1620 with regard to liquidity coverage requirement, Article 25 states that other retail deposits shall be subject to higher outflow rates, as determined by the credit institution, in accordance with paragraph 3, where certain conditions are met including “the deposit is an internet-access only account”. Earlier on EBA has provided a comment in the Q/A question ID: 2019_4890 that “a retail deposit account, which can exclusively be serviced by telephone as well as by internet, should trigger the “internet access only” risk factor for high outflow classification”. However, this explanation is ambiguous for the challenger banks and fintechs whose clients specifically use mobile apps to sign up, log in, top up, use the features like payments, open savings accounts, invest, etc. These institutions tend to offer their clients virtual and/or physical cards. Physical card owners can access their funds via ATMs.

Submission date
Rejected publishing date
Rationale for rejection

This question has been rejected because the issue it deals with is already explained or addressed in Article 25(2)(b) of the COMMISSION DELEGATED REGULATION (EU) 2015/61.

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.

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Status
Rejected question