Reporting of retail deposits to internet banks that are also partly used as collateral for various broker services such as forex and other OTC derivatives.

As per Commission Delegated Regulation EU of 10.10.2014 to supplement Regulation 575/2013 with regard to liquidity coverage requirements for credit institutions, it is stated that outflows from other retail deposits should be treated according to Article 25. Does this include retail deposits that are also partly used as collateral for broker services?

According to Article 25 other retail deposit should be scored on a scale according to a number of criteria 19s in Article 25 (2), yet it is unclear if retail cash deposits that qualify as collateral fall under this category or if they should rather be treated according to Article 30 (6). Retail clients have significantly different behaviour than financial clients and typically have deposits of which only a small part is used for broker services compared to financial clients. It would therefore appear as though Article 30 (6) is intended for financial clients and Article 25 for retail clients deposits. Example: A retail customer has a deposit of EUR 200 in cash on his or her account. The customer opens a derivative position that gives rise to a collateral pledge requirement of EUR 40 (initial margin) from the Bank. The client thereby has an unpledged deposit of EUR 160, and a pledged deposit of EUR 40. Should the unpledged part of the deposit (EUR 160) be treated according to article 25 (outflow 10-20% depending on criteria in article 25(2-3)), or alternatively according to article 30(6) - (100% outflow)?