Regardless of the provisions of Article 10 of Commission Delegated Regulation (EU) 2015/61, which includes assets representing claims on or guaranteed by the European Central Bank as Level 1 Liquid Assets, confirmation is requested on the possibility of treating the amounts deposited on the ECB  “Marginal Deposit Facility” as liquidity inflow for determination of the Liquidity Coverage Requirement (LCR ratio), based on the provisions of Article 32 of Commission Delegated Regulation (EU) 2015/61, which states:

2.   Credit institutions shall apply a 100 % inflow rate to inflows referred to in paragraph 1, including in particular the following inflows:

(a) monies due from central banks and financial customers with a residual maturity of no more than 30 calendar days;

We understand that making an overnight deposit with the ECB should not have a more penalizing treatment than making an overnight deposit with another credit institution, regardless some entities may decide to consider the amounts deposited on the Marginal Deposit Facility as a Level 1 Liquid Asset, due to different reasons (i.e., the 75% of inflows cap). 

This possibility would also be endorsed as provided for in delegated regulation 2021/451,

APPENDIX XXIII - instructions for reporting on the maturity ladder:

Row 640 - 2.2.5 central banks

The amount of cash inflows reported in row 590 that derives from central banks

Row 740 + 3.2 Withdrawable central bank reserves

Total amount of reserves at central banks in accordance with point (b)(iii) of Article 10(1) of Delegated Regulation (EU) 2015/61 withdrawable overnight at the latest Securities representing claims on or guaranteed by central banks shall not be reported here.