Nostro/vostro accounts between different institutional units of the same credit institution
Could you please explain whether nostro/vostro accounts that are exchanged between different institutional units of the same credit institution are subject to AnaCredit reporting?
Any instrument within the meaning of Article 1(23) of the AnaCredit Regulation that is exchanged between distinct counterparties is subject to AnaCredit reporting. In general, a nostro/vostro account with a debit balance will constitute an instrument as defined by Article 1(23) and will therefore be reportable to AnaCredit.
If nostro/vostro accounts are exchanged between different institutional units of the same credit institution, they are reportable to AnaCredit where the different institutional units involved are distinct counterparties. Moreover, the balance of the account will determine which counterparty is reported as the creditor and which is reported as the debtor. Let’s consider the following example:
A credit institution runs a nostro/vostro account, which it uses to settle (intracompany) transactions with its foreign branch.
Initially, on 31 March 2019, the balance of the nostro/vostro account is such that the credit institution (as represented by its head office) has a claim on the foreign branch. In this case, an instrument (e.g. “deposits other than reverse repurchase agreements”) is reported to AnaCredit, whereby the head office is reported as both the creditor and the servicer and the foreign branch is reported as the debtor.
Later, on 30 April 2019, the balance of the nostro/vostro account is such that the foreign branch has a claim on the head office of the credit institution. In this case, the foreign branch is reported as the creditor and the head office is reported as both the debtor and the servicer (with the account representing a nostro account from the perspective of the foreign branch).