QA2018-22 - Subordinated liabilities T01.00

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Feb 01, 2024
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Resolution Reporting Subject Matter Guidance
Guidance Documents Subordinated-Liabilities
Taxonomy -
Unique Identifier

QA2018-22

Question


For T01.00 could you please clarify, in which line non-preferred Schuldschein loans (i. e. deposits according to German Deposit Guarantee Scheme should be reported? There was guidance for the 2016 data, those should be reported in line r380 (Other MREL eligible liabilities). But since Schuldschein loans which are held by preferred creditors should be reported in line r310 (deposits, not covered but preferential) and for line r380 the guidance requests “minimal usage” there seems to be good reason for using line r320 (Deposits, not covered and not preferential) instead.


Response


If these instruments can be understood as being 'deposits' this classification in r320 seems appropriate. For such specific instruments, it is however adviseable to contact the IRT to agree on the understanding of specific instruments and agree on the correct reporting format.