- Question ID
-
2015_2030
- Legal act
- Regulation (EU) No 575/2013 (CRR)
- Topic
- Liquidity risk
- Article
-
425
- Paragraph
-
2
- 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 2 (ii)
- Name of institution / submitter
-
HSBC Holdings plc
- Country of incorporation / residence
-
UK
- Type of submitter
-
Credit institution
- Subject matter
-
For trade finance transactions within 30 days to maturity the DA indicated a 100% inflow for financial customers, however we understand this was for all customers
- Question
-
Regulation (EU) No 575/2013 article 425 2 (b) indicates that monies due from trade finance transactions within 30 days are a taken account in full. However the Delegated Regulation (EU) 2015/61, article 32 2 (a) and its associated sub paragraph (ii) read as if this only relates to financial customers, therefore are trade finance trascations from non-financial customers less than 30 days to maturity to be taken into account in full as inflows?
- Background on the question
-
There seems to be a clash between the Delegated Act and the CRR on trade finance transaction inflows from non-financial customers. We understand this was not meant to the case and all trade finance transactions within 30 days should be counted as 100% inflows
- Submission date
- Rejected publishing date
-
- Rationale for rejection
-
Please note that as part of adjustments to the Single Rulebook Q&A process, agreed by the EBA and the European Commission, it has been decided to reject outstanding questions submitted before 1 January 2020, when the Q&A process was updated as part of the last ESAs Review. In particular, the question that you have submitted has now regrettably been rejected and will not be addressed.
If you believe your question would still benefit from clarification, you are invited to resubmit your question, adapting it to reflect any legislative, regulatory or other relevant developments that may have occurred since the initial date of submission. The EBA will aim to address resubmitted questions as a matter of priority. When considering to resubmit, you are kindly requested to observe the updated admissibility criteria agreed in the context of the adjustment of the Q&A process, available in the Additional background and guidance for asking questions. We hope for your understanding.
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- Status
-
Rejected question