We noticed that there is a different understanding of how to present loans and deposits which are granted earlier than Reporting date, and which are fully matured on Reporting date. 

1. One opinion is that for F5.01 and F8.01 only original maturity should be used (i.e. fully matured term loans should be presented as term loans). 

2. The other opinion is that fully matured loans and deposits should be presented only as on demand/current account.

Note: In Q&A 2023_6908 question and answer was: how should be presented "Loans and receivables" or "Deposits" which are granted earlier than Reporting date, but which will be matured/repaid on the day following Reporting date.

Regulations which are from our point of view relevant for this topic:

• Annex V paragraph 85(a):

(a) ‘on demand (call) and short notice (current account)’ shall include balances receivable on demand (call), at short notice (by close of business on the day following that on which the demand was made), current accounts and similar balances including loans that are overnight deposits for the borrower (loans to be repaid by close of business on the day following that in which it was granted), regardless of their legal form. It shall also include ‘overdrafts’ that are debit balances on current account balances and compulsory reserves held at the central bank;

(b) ‘Credit card debt’ shall include credit granted either via delayed debit cards or via credit cards as defined in the Table of Part 2 of Annex II to the ECB BSI Regulation; 

(c) ‘Trade receivables’ shall include loans to other debtors granted on the basis of bills or other documents that give the right to receive the proceeds of transactions for the sale of goods or provision of services. That item shall include all factoring and similar transactions, like acceptances, outright purchase of trade receivables, forfaiting, discounting of invoice, bills of exchange, commercial papers and other claims where the reporting institution buys the trade receivables (both with and without recourse); 

(d) ‘Finance leases’ shall include the carrying amount of finance lease receivables. Under IFRS, ‘finance lease receivables’ are as defined in IAS 17;

(e) ‘Reverse repurchase loans’ shall include finance granted in exchange for securities or gold bought under repurchase agreements or borrowed under securities lending agreements as defined in paragraphs 183 and 184 of this Part;

(f) ‘Other term loans’ shall include debit balances with contractually fixed maturities or terms that are not included in other items; 

(g) ‘Advances that are not loans’ shall include advances that cannot be classified as loans in accordance with the Table of Part 2 of Annex II to the ECB BSI Regulation. That item shall include, among others, gross amounts receivable in respect of suspense items (such as funds that are awaiting investment, transfer, or settlement) and transit items (such as cheques and other forms of payment that have been sent for collection).

• Annex V paragraph 97:

               ‘Deposits’ and the product breakdown shall be defined in accordance with the Table of Part 2 of Annex II to the ECB BSI Regulation. Regulated savings deposits shall be classified in accordance with the ECB BSI Regulation and distributed according to the counterparty. In particular, non-transferable sight savings deposits, which although legally redeemable at demand are subject to significant penalties and restrictions and have features that are very similar to overnight deposits, shall be classified as deposits redeemable at notice.

• ECB BSI Regulation:

9.1 Overnight deposits which are convertible into currency and/or which are transferable on demand by cheque, banker’s order, debit entry or similar means, without significant delay, restriction or penalty. This item includes: 

(a) balances (interest-bearing or not) which are immediately convertible into currency on demand or by close of business on the day following that on which the demand was made, without any significant penalty or restriction, but which are not transferable; 

(b) balances (interest-bearing or not) representing prepaid amounts in the context of e-money, e.g. prepaid cards; 

(c) loans to be repaid by close of business on the day following that on which the loan was granted; 

(d) notional cash pool positions which are overnight deposits held in notional cash pools by pool participants.”

9.2. Deposits with agreed maturity Non-transferable deposits which cannot be converted into currency before an agreed fixed term or that can only be converted into currency before that agreed term provided that the holder is charged some kind of penalty. This item also includes administratively regulated savings deposits where the maturity related criterion is not relevant; these should be classified in the maturity band ‘over two years’. Financial products with roll-over provisions must be classified according to the earliest maturity. Although deposits with agreed maturity may feature the possibility of earlier redemption after prior notification, or may be redeemable on demand subject to certain penalties, these features are not considered to be relevant for classification purposes.

9.3. Deposits redeemable at notice Non-transferable deposits without any agreed maturity which cannot be converted into currency without a period of prior notice; before the expiry the conversion into currency is not possible or possible only with a penalty. They include deposits which, although perhaps legally withdrawable on demand, would be subject to penalties and restrictions according to national practice (classified in the maturity band ‘up to and including three months’), and investment accounts without period of notice or agreed maturity, but which contain restrictive drawing provisions (classified in the maturity band ‘over three months’).

9.4. Repos Counterpart of cash received in exchange for securities sold by reporting agents at a given price under a firm commitment to repurchase the same or similar securities at a fixed price on a specified future date. Amounts received by reporting agents in exchange for securities transferred to a third party, i.e. the temporary acquirer, are to be classified under ‘repurchase agreements’ where there is a firm commitment to reverse the operation and not merely an option to do so. This implies that reporting agents retain all risks and rewards of the underlying securities during the operation. The following variants of repo-type operations are all classified under ‘repurchase agreements’: 

(a) amounts received in exchange for securities temporarily transferred to a third party in the form of securities lending against cash collateral; and 

(b) amounts received in exchange for securities temporarily transferred to a third party in the form of a sale/buy-back agreement. 

The securities underlying repo type operations are recorded following the rules in asset item 3 ‘debt securities’. Operations involving the temporary transfer of gold against cash collateral are also included under this item.

• Annex XVI of Instructions for disclosure of risk management objectives and policies, exposures to credit risk, dilution risk and credit quality:

- When a counterparty has a choice of when an amount is repaid, the amount is allocated to column ‘on demand’. The column includes balances receivable on demand (call), at short notice, current accounts and similar balances (which may include loans that are overnight deposits for the borrower, regardless of their legal form). It also includes ‘overdrafts’ that are debit balances on current account balances;

 - When an exposure has no stated maturity for reasons other than the counterparty having the choice of the repayment date, the amount of this exposure shall be disclosed in column ‘no stated maturity’.

 - When the amount is repaid in instalments, the exposure shall be allocated in bucket corresponding to the last instalment. 

Note: time buckets based on Annex XV - Disclosure of credit risk quality, Template EU CR1-A: Maturity of exposures are: On demand, <= 1 year, > 1 year <= 5 years, > 5 years, and No stated maturity. Our understanding is that here fully matured loans should be presented as "On demand".