QA2018-30 - Deposits T01.00

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QA2018-30

Question


In your draft guidance you state (page 8/52), regarding row 110 - Covered deposits (BRRD art. 44/2/a : ) : β€˜On an individual basis, the total value of this line corresponds to the data reported to the fund (SRF_2A3).’ In our view this cross-reference cannot be made : indeed in the latest SRF instructions (2018 exercise) the amount to be reported is the average of covered deposits as of the end of the four past quarters and not the amount at 31/12. Moreover, the SRB template based on 31/12/N data has to be submitted in April N+1, before the SRF template (to be submitted in January N+2).


Response


Indeed, the reporting periods for the SRB LDT data template and the SRF CCS data templates do not coincide. However, the reference is made in respect of the definition of the item as such, not with regard to the date at which the item is reported.