EBA · 2020_5156 Final Q&A

Treatment of impediments to the availability of assets and cash inflows in the C 66.00 maturity ladder template

Regulation
Regulation (EU) No 575/2013 (CRR)
Article
415, para. 3
Topic
Supervisory reporting - Liquidity (LCR, NSFR, AMM)
Submitted by
Competent authority
Submitted
2020-03-03
Answered
2020-12-04
Answer provided by
ESAs (EBA, ESMA, EIOPA)

Question

How should potential impediments to the availability of assets and cash inflows be considered in the C 66.00 maturity ladder template?

Background

It has been observed that institutions do no follow one common approach in the reporting of assets and cash inflows that might be unavailable or ‘trapped’.

Answer

In accordance with paragraph 6 of Part I of Annex XXIII of Regulation (EU) No 680/2014 amended by Regulation (EU) No 1627/2018, contractual cash inflows shall be reported in the maturity ladder template. However, only inflows pursuant to performing, non-past due contracts valid at the reporting date shall be included, as clarified in Q&A 2018 3794 . Regarding Counterbalancing capacity (Section 3), paragraph 7 states: ““Counterbalancing capacity” shall represent the stock of unencumbered assets or other funding sources which are legally and practically available to the institution at the reporting date to cover potential contractual gaps.” Furthermore, the template instructions regarding counterbalancing capacity highlight that the definition of encumbered assets in accordance with Commission Delegated Regulation (EU) 2015/61 shall apply. To the extent the sole impediment to the availability of performing assets or inflows would relate to their location in a third country where there are restrictions to the free transferability of liquidity to other countries, a treatment should apply analogous to Commission Delegated Regulation (EU) 2015/61, Articles 8(2) and 32(8). Therefore, such assets / inflows shall be in the (consolidated) maturity ladder only to the extent that they are used to / correspond to outflow s respectively in the third country or currency in question.

Original source: European Banking Authority, Q&A ID 2020_5156

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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