Clarification on use of prearranged and highly reliable funding arrangements

If a CSD-banking service provider has routine credit at a central bank of issue in the EU, are the requirements in Article 11, paragraph 1, subparagraphs (b) and (d) simultaneously met?

The requirements for collateral referred to in Article 11(1) should meet all conditions, among others: they should be eligible at a central bank of the Union where the CSD-banking service provider has routine credit (subparagraph b) and the CSD-banking service provider should have a prearranged funding arrangement specified in Article 38, which provides for the conversion of these instruments into cash on a same-day basis.   Article 38 in turn, provides the requirements which arrangements have to meet in order to be qualified as “prearranged and highly reliable funding arrangements” (PAFA). This includes (among others) a concentration limit on each financial institution involved in such a PAFA with the CSD-banking service provider (paragraphs 4 and 5). However, there seems to be a possibility for the CSD-banking service provider to qualify access routine credit at the central bank of issue as PAFA as well, given that paragraph 6 states that there is no need to have multiple arrangements in (major) currencies when the CSD-banking service provider has collateral that is eligible for pledging to the relevant central bank.