Operational deposits in NSFR

Should operational deposits 422(3)(c) and part of 422(3)(a) not covered by DGS should be reported in ID 1.2.8 (row 250 of C61 ASF) – ‘any other liabilities’ or in IDs 1.2.2.3 and 1.3.3.3 of C61 (ASF)? Current instructions appear contradictory and may lead to inconsistent reporting.

Instruction in ITS on Supervisory reporting on NSFR (C61) appear contradictory to the template in respect of presentation of the Operational deposits from non-financial and financial customers. According to the ITS: • IDs 1.2.2.3 and 1.3.3.3 of C61 (ASF) should include ‘liabilities that qualify for treatment in Article 422(3) and (4)’. These rows are greyed out (should represent the sum of underlying rows (rows 110-130 and 180-200 respectively). • IDs 1.2.2.3.1-3 and 1.3.3.3.1-3 of C61 (ASF) Rows 110-130 and 180-200 only represent a part of the operational deposits listed in Article 422(3) and (4) i.e. 422(3)(b), 422(3)(d) and part of 422(3)(a) covered by DGS. • This means that the IDs 1.2.2.3 and 1.3.3.3 of C61 (ASF) do not include operational deposits 422(3)(c) and part of 422(3)(a) not covered by DGS, and therefore cannot represent a full scope of ‘liabilities that qualify for treatment in Article 422(3) and (4)’. Were IDs 1.2.2.3 and 1.3.3.3 of C61 not meant to be the sum of IDs 1.2.2.3.1-3 and 1.3.3.3.1-3 respectively? Or does it mean that the operational deposits 422(3)(c) and part of 422(3)(a) not covered by DGS should be reported in ID 1.2.8 (row 250 of C61)?