EBA · 2024_7090 Final Q&A

Own secured debt issues in Top 10 - C71.00

Regulation
Regulation (EU) No 575/2013 (CRR)
Article
415
Topic
Supervisory reporting - Liquidity (LCR, NSFR, AMM)
Submitted by
Credit institution
Submitted
2024-05-20
Answered
2025-02-21

Question

Does the secured debt instruments issued by the reporting institution (own issues retained) be reported in the Top10 in C71?

Background

It is clear that own-covered bonds and own-ABS, meaning secured debt instruments issued by the reporting institution retained on the institution’s balance sheet and to which the institution has direct access at its level of consolidation (regardless of whether they are CB-eligible, and reagrdless of whether they are pre-positioned at a central bank for standard liquidity operations) are part of the Counterbalancing capacity to be included both in C66 and C71. But the issuer being the same as the reporting institution, it is not clear whether these assets could be reported as one of the top 10 issuers (to the extent that these assets fall under the top 10 issuers), or whether they should be reported always in Row 120 (2. ALL OTHER ITEMS USED AS COUNTERBALANCING CAPACITY), leaving the top 10 for third party issuers/counterparties.

Answer

According to Annex XXI of Regulation (EU) 2021/451 – ITS on supervisory reporting, point 1, template C 71.00 'collects information about the reporting institutions’ concentration of counterbalancing capacity by the ten largest holdings of assets or liquidity lines granted to the institution'. In addition, point 3 clarifies that the 'counterbalancing capacity in C 71.00 shall be the same as that in C 66.01'. Point 6 further clarifies that 'concentrations of counterbalancing capacity with a central bank as issuer or counterparty shall not be reported in this template' as individual issuer. Given the above, to the extent that the secured debt instruments issued by the reporting institution and retained are part of the counterbalancing capacity of the institution (e.g. they fall into the scope of C 66.01 reporting - initial stock - column 0010), the institution falls under the top 10 issuers and the instruments are unencumbered to be available for the institution to convert into cash on the reporting reference date, then the reporting institution shall be reported as the issuer of such instruments for the purpose of C 71.00. The product type to be reported would be the type of secured debt instruments that have been retained, in line with point 2 of Annex XXI.

Original source: European Banking Authority, Q&A ID 2024_7090

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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