Central bank eligibility of cash

Should cash be reported as central bank eligible in F 32.01 (AE-ASS) if a bank can borrow securities against cash from the central bank?

By borrowing money from the central bank (CB) with a security as collateral, a bank can obtain additional liquidity. By borrowing securities from the CB with cash as collateral, a bank decreases its liquidity, hence reporting cash as CB eligible seems counterintuitive in the context of liquidity and asset encumbrance reporting. Given divergent guidance on the CB eligibility of cash in different reporting templates (see details below) and unclear prudential rationale for reporting cash as CB eligible, we would like the EBA to confirm whether cash should be reported as CB eligible. There is no harmonized approach to reporting of the central bank (CB) eligibility of cash across different reporting templates: F 32.01 (Q&A 2017_3619): sight or term deposits at the CB should be treated as CB eligible only if they are accepted as collateral by the CB; C71 (Q&A 2019_4818): CB deposits may be reported as “CB eligible” if these deposits can be withdrawn during stress period (the answer implies that the “full amount” of not CB eligible deposits may be reported as CB eligible in C71 as long as they can be withdrawn during stress); C 66 (Q&A 2020_5646): withdrawable CB reserves (cash at CB) should not be reported as CB eligible (row 1230), even if they are CB eligible.