Treatment of deposits pledged as collateral against loans in c66.01

How should deposits pledged as collateral against loans be reported in c66.01?

According to the applicable instructions for row 0260 (section “Outflows”) of c66.01 (Reg. (EU) 2021/451 Annex XXIII), deposits received as collateral are exempted from this row. This is also reflected in the label of the row.  From the instructions, it is unclear whether the relevant outflow of these deposits (at the maturity date of the loan against which the collateral is provided) should be reported in a different row or be excluded from the maturity ladder scope. In our view, the outflow should be reported, otherwise there would be a mismatch due to the expected inflow from the collection of the loan and the zero corresponding outflow of the deposit. This approach would be in line with the conservative treatment described in par. 12 of the applicable instructions, where rules are provided for the allocation of the outflows arising from all types of deposits. As regards the row where this outflow should be reported, there are two options: i) the relevant amount shall be netted against the inflow from the collection of the loan (in the relevant row of item 2.2 “Monies due not reported in 2.1 resulting from loans and advances granted to” or ii) the relevant amount shall be reported in row 0370 “Other outflows” given that they do not fall into any of the other available rows.