Prudential Regulation Authority Rulebook

4.1

This chapter sets out the PRA’s expectations of how firms will mark eligible deposits and accounts and is intended to be read together with Chapters 11 and 13 of the Depositor Protection Part.

4.2

Depositor Protection 11.1 sets out that a firm must mark eligible deposits in a way that allows for immediate identification of such deposits. The PRA considers that firms can meet this requirement in a number of ways, including but not limited to:

1. (a) marking eligible (and/or ineligible) deposits at core systems level (ie flagging at account level);
2. (b) a separate file showing eligible (and/or ineligible) deposits; or
3. (c) using the Single Customer View (SCV) file and exclusions view file.

4.3

For the purposes of meeting Depositor Protection 11.1, the PRA considers the marking of eligible deposits may be achieved by marking accounts of eligible depositors which contain eligible deposits. For the avoidance of doubt, where such an account has a nil balance, or the balance becomes negative, the PRA does not expect firms to remove the eligible deposit marker.

4.4

The PRA’s preferred approach to marking is for firms to produce a list of eligible accounts and a list of ineligible accounts, or clearly be able to separately identify both within core systems. If a firm can only produce/show one of these, the PRA expects the firm to give confirmation that the remaining accounts not marked are ineligible or eligible (whichever are not marked).

4.5

In both options 4.2(b) and 4.2(c), the expectation is for files to be produced or updated on a rolling daily basis or where no rolling daily files are updated or produced, capable of being generated immediately following any request from the PRA or the FSCS. Such an approach to SCV and exclusions view file under 4.2(c) is not a requirement under the depositor protection rules, but is an option for firms to use to meet Depositor Protection 11.1. The requirements around the timing and content of SCV and exclusions view file production remains as specified in the relevant rules.

4.6

Deleted.

4.7

For the avoidance of doubt, the PRA considers the separate file (generated under whichever option) only need contain a list of eligible and/or ineligible unique identification account numbers and does not need to include any customer or balance information.

4.8

Deleted.

4.9

The options above would similarly apply to Depositor Protection 11.2.

4.10

The PRA expects that in compliance with the requirement in Depositor Protection 11.1 to 11.2 to mark eligible deposits/accounts ‘in a way that allows for the immediate identification of such deposits’, a firm must be able to make the details of such eligible and/or ineligible accounts (separately identified) available to the PRA or FSCS in a format consistent with the relevant rule and this statement and within twelve hours from the point of a request from the PRA or the FSCS.

4.11

The PRA does not consider that any aggregation of data on a per depositor/legal entity basis is necessary to meet the marking requirements.

4.12

Depositor Protection 13.2 sets out that a firm must mark accounts which hold:

1. (i) eligible deposits of natural persons and micro, small and medium-sized enterprises (SMEs); and
2. (ii) such deposits that would be eligible if they had not been made (ie are held in an account) at a branch of the firm located outside of the UK or Gibraltar.

4.13

The PRA considers that firms can meet the Depositor Protection 13.2 requirements set out above in a number of ways, including but not limited to:

1. (a) marking relevant natural person and SME accounts at core systems level (ie flagging at account level);
2. (b) a separate file showing relevant accounts; or
3. (c) using the SCV and exclusions view file (to meet requirement 4.12(i) only).

4.14

The PRA expects that in compliance with the requirement in Depositor Protection 13.2 to mark accounts ‘in a way that allows for the immediate identification of such accounts’, a firm must be able to make the details of such marked accounts available to the PRA or FSCS in a format consistent with the relevant rule and this statement, and within 24 hours from the point of a request from the PRA or the FSCS.

4.15

If firms wish to use options 4.13(a)–4.13(c) to meet the marking requirement, the same considerations as in paragraphs 4.5 to 4.7 would apply.

4.16

Requirement 4.12(ii) cannot be met by 4.13(c) as SCV files and exclusions view files do not capture non-eligible deposits.

4.17

For a firm marking an account under Depositor Protection 13.2, the PRA considers that an overall marker of natural person/SME status, rather than differentiation between natural persons, micro, small and medium-sized enterprises, would be sufficient.

4.18

Where an account is subject to marking under more than one of Depositor Protection 11.1, 11.2 and 13.2, the PRA expects that a firm would be able to identify the account for each and all of those requirements.

4.19

Deleted.

4.20

Deleted.

4.21

Deleted.

4.22

Deleted.

4.23

Deleted.

4.24

Deleted.

4.25

Deleted.

4.26

Deleted.