Treatment of wholesale term deposits with early withdrawal penalty clauses for maturity ladder purposes

In accordance with paragraph 12, letters (a) and (b) of Annex XXIII of the EBA IT solutions applicable under Commission Implementing Regulation (EU) 2024/3117, where an option to defer payment or receive an advance payment exists, the option shall be presumed to be exercised where it would advance outflows from the institution or defer inflows to the institution. Therefore, wholesale term deposit outflows should be reported in the time bucket corresponding to the early withdrawal option, regardless of any penalties. Penalties shall be considered in the outflows if they impact them. Any options subject to the institution's discretion should be excluded from the treatment, except in cases where it is presumed to be exercised. To this regard, an option shall be presumed exercised where there is a market expectation that the institution will do so; in such cases outflows and inflows should be included in the relative time bucket” Conversely, letter (e) of the same paragraph establishes an exception to this general framework, applicable exclusively to retail term deposits that fulfill point (b) of Article 25(4) of Delegated Regulation (EU) 2015/61.