Determination of the amount of eligible receivables from trade debtors as well as fees or commissions receivable within 30 days as liquid assets in accordance with Article 43(3) of the IFR

Article 43 of Regulation (EU) 2019/2033 (IFR) defines the liquidity requirements for investment firms. Paragraph 3 of that article allows small and non-interconnected investment firms, as well as other investment firms that do not perform activities (3) and (6) of Section A of Annex I to Directive 2014/65/ EU, to include receivables from trade debtors as well as fees or commissions receivable within 30 days in their liquid assets. In order to be eligible, these receivables must: i) account for up to a maximum of one third of the minimum liquidity requirements as referred to in paragraph 1 of this Article; ii) not be counted towards any additional liquidity requirements required by the competent authority for firm‐ specific risks in accordance with point (k) of Article 39(2) of Directive (EU) 2019/2034; iii) be subject to a haircut of 50%.  The conditions included in Article 43(3) of the IFR must all be satisfied at the same time, and the order in which they are listed should not be intended as a sequential approach. The following example exemplifies the calculation. An investment firm, in scope of Article 43(3) of the IFR, presents the following data: fixed overheads: 1 million euro; receivables from trade debtors (in scope of Article 43(3) IFR): 100,000 euro; fixed overhead requirement (Art. 13 IFR) = 250,000 euro (one quarter of the fixed overheads); liquidity requirement (Art. 43(1) IFR) = 83,300 euro (one third of the fixed overheads requirement). According to Article 43(3) of the IFR, the maximum amount of receivables that can be included in the liquid assets should be calculated as follows: receivables after the application of the haircut (Art. 43(3)(c) IFR) = 50,000 euro (50% of 100,000 euro); maximum amount eligible for the purposes of Article 43(1) IFR, calculated according to Article 43(3)(a) IFR: 27,700 euro (one third of 83,300 euro); maximum amount of receivables that can be included in the liquid assets pursuant to Article 43(1) IFR = 27,700 euro.