Clarification of the requirement to establish concentration limits on liquidity providers and establish at least two arrangements for each major currency.

In conjunction with REGULATION (EU) No 909/2014 Article 59(4)(e), does Regulation (EU) 2017/390 Article 38(5) stipulate a requirement to have at least two arrangements in place in each major currency to convert collateral or assets into cash using prearranged and highly reliable funding only? Does the requirement to establish concentration limits and to have at least two arrangements in place include alternative liquidity arrangements such as committed unsecured lines of credit or committed FX swap facilities?

1. It is unclear to what extent Regulation (EU) 2017/390 (EBA RTS) Article 38(5) considers arrangements to convert collateral into cash only, or takes into account all liquidity providers with which a CSD-banking service provider may establish arrangements for its qualifying liquid resources. Commission delegated regulation 2017/390 • Article 36 paragraph 2 stipulates that the CSD-banking type provider shall ensure that each liquidity provider of its minimum required qualifying liquid resources has sufficient information to understand and manage its associated risk • Article 36 paragraph 7.b. stipulates that the scenarios used in stress testing of liquid financial resources shall take into account the temporary failure of one of its liquidity providers to provide liquidity, including those referred to in point (e) of Article 59(4) of Regulation (EU) No 909/2014, custodian banks, Nostro agents, or any related infrastructure, including interoperable CSDs • Article 38.5 requires that a CSD-banking service provider’s liquidity risk management framework shall include a requirement to establish concentration limits, providing the following (a) that the concentration limits are established by currency (b) that at least two arrangements for each major currency are in place (c) that the CSD-banking is not overly reliant on any individual financial institution when all currencies are taken into account 2. A CSD-banking service provider may choose to not accept collateral in a currency, although the currency is considered as major as a result of the analysis made under the provisions of Article 38 Paragraph 5, because the available collateral does not satisfy minimum requirements. In such a scenario the CSD-banking service provide would mitigate the liquidity needs with alternative liquidity sources available such as committed lines of credit or similar agreements such as committed FX facilities..