Undrawn credit facility from central bank as inflow

Can you please confirm that any undrawn credit facility from a central bank counts as a liquidity inflow within the meaning of Article 32 of the LCR delegated act with a 100% inflow rate according to paragraph 2 of Article 32 of the delegated act, provided that there is no double counting with liquid assets and is not taken into account under Article 34 of the delegated act?

A distinction is made between liquidity facilities and credit facilities. The definition for this distinction is given from an outflow perspective in Article 31(1) of the delegated act. According to Article 12(1)(d) of the delegated act, restricted-use committed liquidity facilities received from a central bank qualify as a level 2B asset provided that the requirements of Article 14 in the delegated act are met. Hence, credit facilities received from the central bank do not qualify as a level 2B asset. From Article 32(3)(g) of the delegated act we conclude that undrawn credit and liquidity facilities from central banks may count as a liquidity inflow. The credit and liquidity facilities referred to in Article 34 and the liquidity facilities that count as a level 2B asset under Articles 12(1)(d) and 14 of the delegated act shall not be taken into account. Central bank inflows in general receive a 100% inflow rate according to Article 32(2)(a) of the delegated act. Thus also a credit facility from a central bank under Article 32(3)(g) of the delegated act would have a 100% inflow rate. This is underpinned by the Liquidity Coverage Ratio reporting template (i.e. Annex XXIV EBA-ITS-2015-04 ITS on reporting for the LCR templates) since row 220 receives 100% standard inflow rate in column 070. The instructions of the inflow sheet (i.e. the following ITS: Annex XXV - Part 3 - EBA-ITS-2015-04 ITS on reporting for the LCR instructions) tells us that row 220 corresponds with the credit facilities referred to in Article 32(3)(g) of the delegated act.