Reporting of Template C_67.00 including Concentration of Funding by Counterparty.

Since there is no clear guidance on how the above item should be treated, we are requesting feedback on whether the EBA has taken stance on how deposits coming through Online Deposits Platforms should be classified in the Concentration of Funding by Counterparty, template C_67.00, and for liquidity purposes in general. In addition, we would be interested in understanding whether such treatment would differ for other purposes such as Financial Reporting – as an example, the bank in the above scenario indicated that these deposits are in fact covered by DGS, hence indicating that for this purpose the counterparty is the direct household.

Institutions shall report the top ten largest counterparties or a group of connected clients that is defined in point (39) of Article 4(1) of Regulation (EU) No 575/2013, where the funding obtained from each counterparty or group of connected clients exceeds a threshold of 1% of total liabilities. Assuming that a Credit Institution is obtaining funding from ‘Online Deposit Platforms’ where the underlying depositors behind the ODPs are the Households. When it comes to report template C_67.00, according to Annex 19 Regulation (EU) 2021/45, sector shall be allocated to each counterparty based on FINREP economic sector classes. However, when it comes to classify the Sector of Counterparty there is no clear guidance of how deposits coming from households through Online Deposit Platforms should be treated. We have an instance where the bank is bundling up the household deposits coming from a fiduciary deposits platform, which is resulting in the funding coming from this ODP being classified as one of the top ten funding sources. In template C_67.00, C015 the bank is reporting the LEI Code of the ‘Fiduciary Bank’. Then, in C030, the Counterparty Sector is being classified as ‘Households’ which are the underlying depositors. To us these two items are contradicting each other since the LEI Code does not represent a Household Counterparty.