Treatment of Central Bank Overnight deposits in ALMM Template C71

Should central bank fixed term overnight deposits be included within ALMM Template C71 Row 120 "ALL OTHER ITEMS USED AS COUNTERBALANCING CAPACITY"?

The treatment of how central bank overnight deposits in template C66 is very clear. However, in template C71 instructions Article 3 states: "The counterbalancing capacity in C 71.00 shall be the same as that in C 66.01 with the qualification that the assets reported as counterbalancing capacity for the purposes of C 71.00 shall be unencumbered to be available for the institution to convert into cash on the reporting reference date." The issue in our opinion relates to the last sentence of this instruction. "....available for the institution to convert into cash on the reporting reference date." Is an overnight fixed term deposit placed with our central bank considered to be available to convert into cash on the reporting reference date? On this basis, should Central Bank Overnight deposits be included or excluded from this template? In contrast, we refer to the definition of counterbalancing capacity as per EBA “Guidelines on Liquidity Buffers & Survival periods 09 Dec 09" of which the “liquidity buffer” is a component which states: “In the case of compulsory minimum reserves, banks need to consider the time horizon over which the reserves may be available. For the shorter time horizon (i.e., at least one week) the entire O/N cash holdings at central banks, including reserves, can be included in the liquidity buffer....."