EBA · 2018_3689 Final Q&A

ALMM - C 70.00 : Reporting on holidays and weekends of internationally active credit institutions with subsidiaries in different countries in ‘Roll-over of funding' template

Regulation
Regulation (EU) No 575/2013 (CRR)
Article
415, para. 3
Topic
Supervisory reporting - Liquidity (LCR, NSFR, AMM)
Submitted by
Credit institution
Submitted
2018-01-31
Answered
2019-12-13
Answer provided by
ESAs (EBA, ESMA, EIOPA)

Question

How should (banking) holidays and weekends be reflected in C 70.00 (zeros, empty lines or constant volumes)? How should an internationally active credit institution with subsidiaries in different countries reflect holidays in different countries and working days in the weekend? Is there a different approach to be taken for non-maturity funding versus term funding in light of weekends and (banking) holidays?

Background

Referring to Annex XIX -INSTRUCTIONS FOR COMPLETING THE ADDITIONAL MONITORING TOOLS TEMPLATE OF ANNEX XVIII, it is stated in part 1.5 in paragraph 12 that “For months with less than 31 days as well as for weekends, irrelevant lines shall be left empty”. According to the instructions lines referring to weekends in that reporting period should be empty. Does this mean these cells do not contain any values (thus not reporting zeros or any other figures)? How should (banking) holidays be reflected in general in C 70.00? In our opinion the following options are possible: • We consider as the credit institution as not having any business (thus reporting zeros) • We consider as the credit institution as not operational (thus reporting no values and leaving the resp. lines empty) • We consider constant volumes (thus reporting the same values as the previous business day) How should an internationally active credit institution with subsidiaries in different countries, reflect holidays in different countries (e.g. HQ in France is operational; Subsidiary in Czech Republic has a holiday)? Furthermore, in certain countries (e.g. Hungary), credit institutions operate in the weekend (on Saturdays), how should this be reflected in the template as this conflicts with the instructions (where it is stated to leave those lines empty)? Is there a different approach to be taken for non-maturity funding versus term funding wrt the new funding/roll-over/matured amount in light of weekends and (banking) holidays?How should deposits be reported which mature during weekends or (banking) holidays? How should transactions (e.g. payments with debit/credit cards) in the weekend and on banking holidays be reflected in the template?

Answer

According to Annex XIX under section 1.5 paragraph 12, for months with less than 31 days as well as for weekends, irrelevant lines in C 70.00 shall be left empty, as in such days institutions are non-operational (or they do not exist in case of months with less than 31 days). Accordingly, holidays and – more in general – non-operational days should follow the same approach. With regard to internationally active banking groups, items in the template shall be left empty as long as all credit institutions within the group are non-operational , meaning that where even only one subsidiary is operational in a given day, relevant items in the template must be completed. According to Annex XIX, non-maturity and term funding should follow the same approach in irrelevant lines of C 70.00 since no difference is envisaged in reporting instructions in this regard.

Original source: European Banking Authority, Q&A ID 2018_3689

This Q&A is published by European Banking Authority and is non-binding. It does not constitute legal advice. Updated weekly from official ESA sources.

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