Question ID
2025_7568
Legal act
Regulation (EU) No 575/2013 (CRR)
Topic
Supervisory reporting - FINREP (incl. FB&NPE)
Article
430
Paragraph
3
Subparagraph
-
COM Delegated or Implementing Acts/RTS/ITS/GLs/Recommendations
Regulation (EU) 2024/3117 - ITS on supervisory reporting of institutions
Article/Paragraph
Annex V, PART 2, paragraphs 2, 3
Type of submitter
Competent authority
Subject matter
Definition of ‘demand deposits’ for FINREP reporting
Question

How to report in FINREP loans and advances on demand and short notice that are not readily available at all times?

Background on the question

We would like to get comprehensive and unified guideline regarding reporting any kind of loans on demand and short notice that are not readily available at all times. The latter means that draw funds is not within the power of the bank, the bank is dependent on the willingness of the debtor whether the claim will be settled or not. 

 

The uncertainty regarding the correct reporting of such exposures was caused by publishing 2 Q&As, each of them treating such exposures differently:

  • In line with Q&A 2024_7191 in case of financial guarantee given on debt of credit institutions that has been called and paid by the bank, the customer’s obligation to reimburse the payment to the bank should be reported in template F 05.01 in row 0010 ‘On demand [call] and short notice [current account]’. Consequently, when the debtor is credit institution, balances are included in template F 01.01 in row 0040 'Other demand deposits'.
  • In line with Q&A 2024_7241 reverse repurchase loans to credit institutions with original maturity of less than or equal to one day should be reported in template F 01.01 as 'loan' in the relevant accounting portfolio following the applicable accounting rules, outside the row 0040 'Other demand deposits'.
Submission date
Final publishing date
Final answer

The instruments included in ‘Loans and advances on demand and short notice’ that are not readily available at all times fall within the definition of “Loans and advances” as set out in the IT solutions to Commission Implementing Regulation (EU) 2024/3117 (Annex V- paragraph 32, Part 1). More specifically, they correspond to the definition of “loans” provided in the table of Part 2 of Annex II to Regulation (EU) 2021/379 (ECB BSI Regulation).

In template F 01.01, provided that the counterparty’s obligation to repayment these loans to the reporting institution is not immediately due and payable, and therefore the amounts are not readily available at all times, these loans should be reported within the relevant accounting portfolio, in accordance with applicable accounting standards, and reported outside row 0040 “Other demand deposits” since they do not meet the definition of “Other demand deposits” as described in paragraph 3 of Part 2 of Annex V. 

Status
Final Q&A
Answer prepared by
Answer prepared by the EBA.

Disclaimer

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