Response to consultation on draft Guidelines on retail deposits subject to different outflows for purposes of liquidity reporting
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We think that salary inflow is enough (even without regular transactions) OR regular transactions (without the salary requirement).
Depositors which have minimum two active products (including products from the Group) can also be classified as that with established relationships.
The local (Polish) DGS amount is equal to the “high value” proposed.
In our opinion the minimum amount of “very high value” deposits could be higher, for example minimum amount of “high value” deposits multiplied by 10 (not by 5) because the “very high value” deposits portfolio should be only a supplement of the “high value” deposits portfolio, not the next stability criterion (this portfolio should be comparatively small).
Do you agree with this criterion for identifying a transactional account?
No, we don’t agree.We think that salary inflow is enough (even without regular transactions) OR regular transactions (without the salary requirement).
Regarding established relationships, how would you assess that the contractual relationship with the institution and the minimum number of products are active in the sense of being actively managed?
Such contractual relationship with the institution could be assessed by having (by depositors) ACTIVE current account OR ACTIVE savings account for at least 6 months.Depositors which have minimum two active products (including products from the Group) can also be classified as that with established relationships.
What is your view concerning the threshold proposed for high and very high value deposits? Please give your reasons.
The thresholds proposed for high and very high value retail deposits seem quite appropriate.The local (Polish) DGS amount is equal to the “high value” proposed.
In our opinion the minimum amount of “very high value” deposits could be higher, for example minimum amount of “high value” deposits multiplied by 10 (not by 5) because the “very high value” deposits portfolio should be only a supplement of the “high value” deposits portfolio, not the next stability criterion (this portfolio should be comparatively small).