- Question ID
-
2022_6460
- Legal act
- Regulation (EU) No 575/2013 (CRR)
- Topic
- Liquidity risk
- Article
-
421
- 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
- Name of institution / submitter
-
ProCredit Holding AG & Co KGaA
- Country of incorporation / residence
-
Germany
- Type of submitter
-
Credit institution
- Subject matter
-
Determination of the total deposit balance of "all the client's deposit accounts"
- Question
-
Assuming a natural person has a bank account at a bank as a private individual. At the same time the individual is a (co)-owner of a legal entity, which qualifies as an SME, and the legal entity has a business account at the same bank.
Shall the accounts of both the private individual and the legal entity be aggregated when checking the total deposit balance against the threshold of EUR 500,000? If so, how would the bank determine the appropriate share of the account balance of the legal entity (SME) if the individual is only a co-owner (e.g. 100%, 50%, etc.)?
- Background on the question
-
According to article 25 paragraph 2 letter a) of DR (EU) 2015/61, other retail deposits shall be subject to higher outflow rates if the total deposit balance, including all the client's deposit accounts at that credit institution or group, exceeds EUR 500,000.
The question relates to the aggregation logic of different deposit accounts at one institution in order to determine the LCR outflow rate and whether or not it exceeds the threshold of EUR 500,00. At the same time the question seeks clarification on the definition of a "client" in the context of DR (EU) 2015/61.
- Submission date
- Rejected publishing date
-
- Rationale for rejection
-
This question has been rejected because the matter it refers to has been answered in Q&A 2020_5322.
- Status
-
Rejected question