Question ID
2025_7338
Legal act
Regulation (EU) No 575/2013 (CRR)
Topic
Supervisory reporting - Liquidity (LCR, NSFR, AMM)
Article
411
Paragraph
16
Subparagraph
b
COM Delegated or Implementing Acts/RTS/ITS/GLs/Recommendations
Delegated Regulation (EU) 2015/61 - DR with regard to liquidity coverage requirement
Article/Paragraph
32
Type of submitter
Individual
Subject matter
Treatment of factoring in LCR and NSFR
Question

For the purpose of Liquidity Coverage Ratio, shall factoring be treated as trade finance (this means to consider a 100% weighted inflow at row 180)?

Background on the question

According to Article  411 (16)(b) of REGULATION (EU) 2019/876 OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL, farctoring shall be treated as trade finance, for the purpose of Title IV (THE NET STABLE FUNDING RATIO). With regard to LCR, the COMMISSION DELEGATED REGULATION (EU) 2015/61, Article 32(2)(a)(ii) does not explicitly mention factoring in the definition of trade finance (referring to Article 162(3) of Regulation (EU) No 575/2013). This lack of explicit reference generates inconsistency between the two templates, because in NSFR factoring, as trade finance, is weighted 0.10 (if the maturity is less than six months), while in LCR factoring is not represented in the trade finance row (row 180, 100% weight) , but in the above unsecured rows based on the counterparty type (with weights which vary from 5% to 100%).

Submission date
Rejected publishing date
Rationale for rejection

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Status
Rejected question