EBA欧洲银行-CP36_Euroclear_2页_90kb

报告摘要

Euroclear Group Response to CEBS Consultation Paper 36 on Liquidity Cost Benefit Allocation

Core Content

Euroclear Group is the world's leading provider of domestic and cross-border settlement services for bond, equity, fund, and derivative transactions. The group is composed of the International Central Securities Depositary (ICSD) Euroclear Bank, based in Brussels, and national Central Securities Depositories (CSDs) in Belgium, Finland, France, the Netherlands, Sweden, and the UK & Ireland. These institutions are user-owned and user-governed, and they operate under the principle of facilitating post-trade processing for their clients.

The Euroclear Group has responded to the consultation paper issued by the Committee of European Banking Supervisors (CEBS) on the Guidelines for Liquidity Cost Benefit Allocation. The response outlines the Group's perspective on how liquidity costs should be allocated within the context of its operations.

Main Views and Key Points

General Comments

Single-Purpose Institutions: Euroclear Bank is a single-purpose institution that operates within a single business line, as defined under Basel II. Its services are focused on facilitating post-trade processing for clients.
Liquidity Needs: The liquidity needs of Euroclear Bank are primarily driven by the intraday credit facilities it offers to its participants. These are used to support the settlement of securities transactions.
Duration of Exposures: The duration of exposures from intraday credit varies depending on the nature of the transactions and the funding sources. Most exposures last less than 24 hours, while some may extend to several hours.
End-of-Day Overdrafts: In unforeseen circumstances such as settlement failures or delayed credits, some exposures may become end-of-day overdrafts. These are retained in the books of Euroclear Bank until the next day.
Liquidity Costs: Euroclear Bank does not face material direct liquidity costs because intraday credit is free of charge. However, indirect liquidity costs may arise from committed facilities obtained from other credit institutions to ensure operational continuity in contingency situations.
Cost Allocation: Euroclear Group believes that allocating liquidity costs at a granular level may not be meaningful for single-purpose institutions, as all business units contribute to the core services they provide. In the case of Euroclear Bank, liquidity risk and costs are predominantly driven by intraday credit, which is related to participant behavior rather than specific products or services.

Specific Comments

Guideline 4: Euroclear Group agrees that both committed and uncommitted credit lines may expose institutions to liquidity risk. However, they argue that charging business units for unconditionally revocable credit lines is not appropriate. This is because the Credit Department at Euroclear Bank, which grants such credit, is not a profit center and does not derive any benefits from the credit provided. As a result, it has no incentives to consume more liquidity than necessary.
Credit Usage and Pricing: The credit usage is related to participant behavior and cannot be unambiguously linked to specific products, services, or business areas. Therefore, charging business units for unconditionally revocable credit lines is not suitable. However, where liquidity needs are clearly related to specific services (e.g., collateral posted in local markets to allow cross-border settlement), the cost of such liquidity is appropriately reflected in the pricing of those services.

Conclusion

Euroclear Group emphasizes the importance of understanding the unique operational model of single-purpose institutions like Euroclear Bank. They argue that liquidity costs should be allocated in a way that reflects the actual sources and nature of the exposures, rather than being arbitrarily assigned to specific business units. Euroclear Group believes that the current structure of their operations ensures that liquidity is managed efficiently and that any associated costs are appropriately accounted for in the pricing of services where applicable.