EBA · 2022_6460 Rejected question

Determination of the total deposit balance of "all the client's deposit accounts"

Regulation
Regulation (EU) No 575/2013 (CRR)
Article
421
Topic
Liquidity risk
Submitted by
Credit institution
Submitted
2022-05-23
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Question

Assuming a natural person has a bank account at a bank as a private individual. At the same time the individual is a (co)-owner of a legal entity, which qualifies as an SME, and the legal entity has a business account at the same bank. Shall the accounts of both the private individual and the legal entity be aggregated when checking the total deposit balance against the threshold of EUR 500,000? If so, how would the bank determine the appropriate share of the account balance of the legal entity (SME) if the individual is only a co-owner (e.g. 100%, 50%, etc.)?

Background

According to article 25 paragraph 2 letter a) of DR (EU) 2015/61, other retail deposits shall be subject to higher outflow rates if the total deposit balance, including all the client's deposit accounts at that credit institution or group, exceeds EUR 500,000.  The question relates to the aggregation logic of different deposit accounts at one institution in order to determine the LCR outflow rate and whether or not it exceeds the threshold of EUR 500,00. At the same time the question seeks clarification on the definition of a "client" in the context of DR (EU) 2015/61.
No answer published yet.

Original source: European Banking Authority, Q&A ID 2022_6460

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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