- Question ID
-
2018_4412
- Legal act
- Regulation (EU) No 575/2013 (CRR)
- Topic
- Liquidity risk
- Article
-
411
- Paragraph
-
2
- COM Delegated or Implementing Acts/RTS/ITS/GLs/Recommendations
- Delegated Regulation (EU) 2015/61 - DR with regard to liquidity coverage requirement
- Article/Paragraph
-
3 (8)
- Type of submitter
-
Credit institution
- Subject matter
-
Counterparty of deposits taken from a fiduciary bank
- Question
-
Do fiduciary deposits that are taken from a fiduciary bank for risk and reward of an underlying retail client qualify as retail deposits as defined in article 3 of the Delegated Regulation 2015/61?
- Background on the question
-
Fiduciary deposits are deposits taken from fiduciary banks for the risk and reward of a retail customer. The retail customer itself is unknown to deposit taker, however in case of a default of the fiduciary bank the retail customer is entitled to the funds on the deposit. The question is whether such fiduciary deposits can be seen as retail deposits. The answer is relevant because the type of counterparty determines the relevant articles to determine the correct outflow percentage that has to be used for the calculation of the liquidity coverage ratio.
- 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.
For further information please refer to the press release and the updated Q&A page.
- Status
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Rejected question