QA2025-3- Tab B01.00 Perimeter confirmation
- SRB Services
| Attribute | Detail |
|---|---|
| Unique Identifier | QA2024-3 |
| Document | MBDT Guidance |
| MBDT Guidance | B01.00 |
| Title | Tab B01.00 Perimeter confirmation |
Question
Please, can you confirm liabilities to be reported in Tab B01.00 are the ones with an insolvency rank up to the insolvency rank reported in tab B02.00? There are various relevant points we’d like to clarify:; # Even being data sets for bail-in are you sure you want to use insolvency ranking instead of bail-in rank or a combination of both? # Tab B02.00 includes secured liabilities which are normally excluded for bail-in. Therefore, almost all of liabilities in most of the countries of Europe are going to be reported. Is the perimeter requirement considering secured liabilities or only the liabilities subject to bail-in of B02.00? # In case point 2 is confirmed. Can the entity directly report all liabilities if it deems it appropriate? We don't see the benefit of excluding a few hundred records out of several million.
Response
It is confirmed that liabilities must be reported in B01.00 “up to the insolvency rank reported in tab B02.00” (see MBDT Guidance, section 2.2). Please note that for mandatorily excluded liabilities, only those ranking pari passu with bail-inable liabilities are requested to be reported, in aggregated form, in B01.00. On the other points raised: (1) It is confirmed that insolvency ranking shall be used in column c0020 of B01.00; (2) Regarding secured liabilities, the MBDT Guidance clarifies in section 1.1, paragraph 11(c), that “The scope of the MBDT for the reporting […] encompasses: […] liabilities secured by a pledge, lien or collateral that must be excluded from bail-in according to Article 27(3)(b) SRMR. This category is included within the scope of the MBDT granular tabs in order to allow the resolution authorities to comply with Article 27(4) SRMR in case of need”. Pursuant to the MBDT Guidance, in tab B01.00 such liabilities would need to be aggregated and reported only if ranking pari passu with bail-inable liabilities. (3) The MBDT sets the minimum scope for the reporting of information relevant for the operationalisation of the bail-in. However, if deemed appropriate, the bank may broaden the scope of B01.00 including all liabilities, regardless of their insolvency ranking.