Question ID:
2017_3502
Legal Act:
Regulation (EU) No 575/2013 (CRR)
Topic:
Supervisory reporting - Funding Plans
Article:
99
COM Delegated or Implementing Acts/RTS/ITS/GLs/Recommendations:
EBA/GL/2014/04 - Guidelines on harmonised definitions and templates for funding plans of credit institutions
Article/Paragraph:
Annex I
Disclose name of institution / entity:
Yes
Name of institution / submitter:
National Bank of Slovakia
Country of incorporation / residence:
Slovak Republic
Type of submitter:
Credit institution
Subject Matter:
Incorrect validation rule - deposits guarantee scheme
Question:

We think that the validation rule v4134_m is incorrect.

Background on the question:

In the template P 02.01 in rows 010 and 020 columns 010 to 050 a bank is reporting deposits covered and not covered by a Deposit Guarantee Scheme according to Directive 94/19/EC or an equivalent deposit guarantee scheme in a third country, including (in row 010): - deposits of towns and municipalities, - deposits of social service homes, - deposits of social service facilities, - deposits of primary schools. All these deposits are covered by the Deposit Protection Scheme (according to the Act of Deposit Protection in Slovakia). On the other hand these deposits can not be reported in the template P 01.02 in rows 020, 060 and 120 columns 010 to 050. Consequently the rule can not be met.

Date of submission:
30/08/2017
Published as Final Q&A:
04/12/2020
EBA Answer:

According to the instructions in Annex I to the EBA Guidelines on harmonised definitions and templates for funding plans of credit institutions (EBA/GL/2014/04), template P 01.02 contains the breakdown of deposits coming from households (as per Annex V Part 1.35(f)), from private non-financial corporates (as per Annex V Part 1.35(e) Non-financial corporations) and coming from financial corporates (as per Annex V Part 1.35(c) - Credit institutions - and (d) - (d) Other financial corporations). Template P 02.01 contains the deposits covered and not covered by a DGS according to Directive 2014/49/EU of 16 April 2014 on deposit guarantee schemes (repealing Directive 94/19/EC) (or equivalent in a third country).


As explained in Q&A 2015_2425, only retail deposits under Article 411.2 of Regulation (EU) No 575/2013 as amended by Regulation (EU) 2019/876 (CRR2)
shall be reported as defined in the references in template P 02.01 of Annex I to Guideline EBA/GL/2014/04.


In reporting framework v2.10, the template has changed the scope in this regard, since the instructions do not refer to 411.2 CRR2 anymore, but to Article 2, paragraph 1(5) of Directive 2014/49/EU on deposit guarantee schemes, i.e. all deposits eligible for compensation for each customer with the credit institution up to EUR 100,000 for each depositor. Temporary high deposit balances which are covered by a deposit guarantee scheme, as per Article 6 (2), should also be reported here. In relation to that change, the v4134_m has been amended for v2.10.

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