Question
Article 425(2)(c) of Regulation (EU) No 575/2013 (CRR) specifies that assets with an undefined contractual end date shall be taken into account with a 20% inflow provided that the contract allows the institution to withdraw and request payment within 30 days. Do current accounts held with other credit institutions fall into that category? If not, how should these current accounts be reported?
Background on the question
Article 425(2) indicates that liquidity inflows shall be reported in full with some specific inflows to be reported separately. Different categories of specific inflows are then listed.
Answer
Article 425(2)(c) of Regulation (EU) No 575/2013 (CRR) states that a 20% inflow rate shall be applied only to the loans assets with an undefined contractual end date where the contract allows the bank to withdraw and request payment within 30 days. Moreover, a 20% inflow may only be applied to these exposures if the institution has no reason to expect non-performance within the 30-day time horizon. Current accounts held with other credit institutions, i.e. nostro account balances, are ‘at call’ and should therefore be treated as overnight deposits, leading to 100% inflow (as there are not reported in the stock of HQLA), which corresponds to the 100% outflow rate applied by the deposit receiving institution. Monies due from current accounts held with other credit institutions may be reported in row 160 980 of Template C74.00 C53.00 (”monies due from financial customers” other inflows), provided the monies can be considered contractual inflows, are not past due and the depositing institution has no reason to expect non-performance of the deposit taker within the 30-day horizon. An exception to the treatment outlined in the preceding paragraph is where the deposits held in current accounts with other institutions are considered operational deposits and the institution owing those monies treats them in accordance with Articles 422(3) and (4) of the CRR. In such cases, the reporting institution shall report the monies due in row 120 070 of Template C74.00 C53.00 and multiply the amount due by a corresponding symmetrical inflow rate based on the applicable outflow rate, 25%, as these deposits cannot be covered by a DGS. See further Q&A 306.