Deposits which represent savings accounts at building societies
In the case of deposits which represent savings accounts at building societies, when a temporary debit arises (owing to initial fees for opening the deposit account), should this be treated as an unauthorised debit on a current account?
Consequently, should this be reported to AnaCredit even though the debit is temporary and unrelated to lending activities?
Section 3.4.1 of Part II of the AnaCredit Reporting Manual explains that the type of instrument “deposits other than reverse repurchase agreements” includes “instruments in the form of deposits placed by observed agents. In no case do deposits received by observed agents fall within the scope of this item”. Additionally, it is clarified that debit balances on current accounts can arise in current accounts that have or do not have a credit limit attached.
Therefore, given that the amount of debit does not originate from a lending-type instrument but is rather purely service-related, and given that the account holder does not have the funds debited and at their disposal, fees incurred when opening a savings account – having been booked in the savings account (thus making it negative) – are not subject to reporting to AnaCredit.
However, if such a fee is booked in an overdraft account or current account with no credit limit resulting in a debit balance, the fee amount (as part of the outstanding amount) is subject to AnaCredit reporting. To that extent, it is clearly indicated on page 84 of Part II of the AnaCredit Manual that “… any unpaid past due interest, penalty fees or other fees charged to the instrument are included in the outstanding nominal amount”.