QA2021-35 - LDR | Intragroup deposits excluded from Bail-in

Owned by SRB Services
Feb 01, 2024
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QA2021-35

Question


Considering that categories/rows mandatorily excluded from Bail-in at LDR T01.00 do not reflect yet this amendment, what is the appropriate classification, for reporting purposes, of liabilities that fall under point h) of article 44 (2) BRRD. In particular, regarding intragroup deposits mandatorily excluded from Bail-in, in our opinion the best option at the moment is to report under r0120 (Secured Liabilities - Collateralized part). We kindly ask your confirmation on this understanding.


Response


Until the LDR is updated to include a specific line reflecting the exclusions under Article 44(2)(h) BRRD, banks should follow the instructions of the SRB 2021 Guidance of the LDR, and report as liabilities excluded from bail-in (in r0100) only the sum of rows r0110, r0120, r0130, r0140, r0150, r0160, r0170, r0180, r0190 and r0200, observing the definitions specified for each of these rules. In relation to intragroup liabilities, banks should also observe the instructions of the SRB 2021 Guidance, reconciling c0020 of tab T0301 with the relevant categories of bail-inable liabilities of T0101. However, being aware of the changes in the perimeter of excluded liabilities introduced by Art. 44(2)(h) BRRD, banks should pay special attention to ensuring that the insolvency ranking reported in column c003 of T0301, as well as the identification of the entity as a part of the resolution group in column c0057 of T0301, are precise enough for the IRT to correctly identify the complete perimeter of excluded liabilities when the conditions of Art. 44(2)(h) BRRD. Based on the information provided in the granular tabs, CIR templates as well as the information from the bail-in playbook shared by the institutions (where the exclusions should not be identified based on the LDR, but on an ad-hoc process), both banks and IRTs are expected to identify the correct perimeters of excluded and bail-inable liabilities for the purpose of MREL setting and resolution planning.