Question ID
2025_7361
Legal act
Regulation (EU) No 575/2013 (CRR)
Topic
Supervisory reporting - Liquidity (LCR, NSFR, AMM)
Article
Annex 19, Section 1.1 (2), Section 1.2 (5)
COM Delegated or Implementing Acts/RTS/ITS/GLs/Recommendations
Regulation (EU) 2021/451 – ITS on supervisory reporting of institutions (repealed)
Article/Paragraph
Article 18
Type of submitter
Credit institution
Subject matter
ALMM total funding – payables
Question

Should liabilities arising from the following payables be considered sources of funding and included in templates C 67.00 and C 68.00 if they are included as financial liabilities in FINREP? Should they also be in scope for templates C 69.00 and C 70.00?

  • Amounts payable in respect of future settlements of transactions in securities, such as trade date payables 
  • Payables in relation to securities fails to receive 
  • Other payables such as brokerage payables (e.g. margin deposits made under derivative contracts, as defined under Regulation (EU) 2021/379, which may not be freely available for on-lending)
Background on the question

The ALMM ITS and related EBA Q&As suggest total funding reported under C67 should match total financial liabilities reported under FINREP. However the more recent EBA Q&A 2023_6956 states that there may be divergences. 

 

Trade date payables, brokerage payables and fails to receive, even if reported as financial liabilities under FINREP, do not represent sources of funding. If material, the inclusion of these items in ALMM would distort the representation of sources of funding risk for a bank (liabilities categories such as deposits, repo, debt securities issued, other subordinated debt). Furthermore, these payables usually mirror trade date receivables for bonds where the credit institutions is a market maker. 

Submission date
Rejected publishing date
Rationale for rejection

This question has been rejected because the objective of the Q&A tool is not to answer questions that put into doubt the correctness of the legal framework or try to lobby for a modification of the text. The Single Rule Book Q&A tool has been established to provide explanations and non-binding interpretations on questions relating to the practical application or implementation of the provisions of legislative acts referred to in Article 1(2) of the EBA’s founding Regulation, as well as associated delegated and implementing acts, and guidelines and recommendations, adopted under these legislative acts. For further information on the purpose of this tool and on how to submit questions, please see 'Additional background and guidance for asking questions'

Status
Rejected question