Question
In which row of the Z02.00 template of the ‘Resolution Planning’ reporting, and in which granular template (Z13.00 or Z16.00), should deposits fully secured by collateral with a value of zero be reported? It should be noted that these exposures are not eligible for bail-in.
Background on the question
One of our subsidiaries carries out fully secured deposit transactions for which the collateral has a value of zero. These are not intragroup transactions, and we have conducted a legal analysis concluding that these transactions are not eligible for bail-in. 1/ In the Z02.00 template, we consider that it is not appropriate to report these transactions under row 310 “Deposits, uncovered but preferred” or row 320 “Deposits, uncovered and non-preferred”, as they are not eligible for bail-in. Among the rows in Z02.00, we have identified the following possible rows: Row 110 “Covered deposits” Row 120 “Secured liabilities – secured part” In our view, the appropriate row in Z02.00 would be row 120, as these transactions do not meet the definition of covered deposits within the meaning of Directive 2014/49/EU and constitute secured transactions backed by collateral. 2/ In our view, these transactions should be reported in the granular template Z13.00 (granular template on deposit transactions). The instructions clearly state that “the scope of this reporting covers all deposits, regardless of the nature or maturity of the deposit, excluding intragroup transactions”. However, we are unable to apply this treatment in practice: from a technical perspective, it is not possible to report these deposits both under row 120 of Z02.00 and in template Z13.00, as row 120 is not available in the list of possible values for column 20 of that template. Therefore, could you please indicate the most appropriate reporting treatment for these transactions in template Z02.00 and in the associated granular template.
Answer
According to the third paragraph of Article 44(2) BRRD, neither (i) the requirement to ensure that all secured assets relating to a covered bond cover pool remain unaffected by the bail-in tool, nor (ii) the exclusion of secured liabilities envisage in Article 44(2)(b) BRRD shall prevent resolution authorities, where appropriate, from applying the bail-in tool in relation to any part of a secured liability or a liability for which collateral has been pledged that exceeds the value of the assets, pledge, lien or collateral against which it is secured. Against this backdrop, it should also be noted that secured finance transactions (such as central bank financing or repurchase agreements) are to be reported in Z 16.00, by netting set. Finally, contrary to the statement made in the question, reference to row 0120 of Z02.00 (Secured liabilities - collateralized part) is available in the list of possible values for Z 13.00;c0020. The value of the pledge, lien or collateral is to be reported in Z 13.00,c0110.