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  1. Homepage
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  4. Mobilisation and Administration of Credit Claims (MACCs)
  5. FAQs - Frequently asked questions

Frequently asked questions (FAQs)

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Frequently asked questions (FAQs)

Because MACCs covers a wide variety of topics and because questions can also arise outside of support hours, this section provides a clear overview of the most frequently asked questions and their answers. The topics can be narrowed down in advance using the search and filter functions.

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  • How do I submit credit claims which have not been issued under German contract law?

    These credit claims cannot be submitted directly to the Bundesbank. This constitutes cross-border use of credit claims, and the CCBM procedure must be used for this purpose. The credit claim must be submitted via the relevant central bank, whose jurisdiction is the basis of the credit claim.

    Bilateral agreements between the central banks involved serve as a basis for cross-border use. For details on the CCBM procedure and on the bilateral agreements in place, please contact the support team credit claims.

  • How is the early termination of a loan or a claim against borrowers’ notes entered in MACCs?

    In the event of early termination, the maturity date must be modified immediately (i.e. at the latest during the next business day) by an update in MACCs.

  • How is the wording “separate” safe custody of borrowers’ notes to be interpreted?

    The counterparty must keep issued borrower’s notes on submitted claims against borrowers’ notes (and thus assigned to the Bundesbank), separate from borrowers notes on claims against borrowers’ notes that have not yet been submitted, e.g. in a separate folder, steel cabinet/vault or in an electronic directory. In the case of an electronic transfer, the counterparty does not acquire possession of the claim against borrowers’ note, which means that it is not subject to the retention obligation pursuant to Section V subsection 2 sentence 3 of the General Terms and Conditions/BBk.

  • How should a credit claim be submitted if the outstanding loan amount increases gradually (e.g. the financing is disbursed as a (construction) project advances? How should this credit claim be identified?

    It is generally possible to submit a credit claim gradually and thus increase the nominal amount of the credit claim submitted, e.g. in terms of (construction) project progress. It should be noted that the total amount of the disbursement of a loan (outstanding loan amount) must correspond to the nominal amount submitted to MACCs. The outstanding loan amount can be updated in MACCs. The date of the first disbursement must always be entered as the value date in MACCs, meaning that the value date will always remain the same over the term of the credit claim. Credit claims that are disbursed as a (construction) project advances must be marked with the “drawn credit line” indicator in MACCs.

  • Is it only necessary to report AnaCredit identifiers in MACCs for credit claims, or is it also necessary for claims against borrowers‘ notes?

    AnaCredit identifiers must be reported in MACCs for all forms of credit claims, including claims against borrowers‘ notes.

  • Is it permissible to submit credit claims on debtors which are not domiciled in the euro area?

    No. According to Section V number 10(3) sentence 2 of the Bundesbank’s General Terms and Conditions, debtors of eligible credit claims must be domiciled in the euro area.

  • Is it possible to submit a consortium member’s share in a consortium loan as a separate credit claim?

    Yes, provided that the eligibility requirements are also met in every other respect (for more details, see our customer information notice of 15 April 2020 regarding the eligibility of consortium loans with pooled collateral, or Section V footnote 12 of the Bundesbank’s General Terms and Conditions).

    Further information

    in German only

    • Information zur Zulässigkeit von Konsortialkrediten mit gepoolten Kreditsicherheiten
      15.04.2020 Vordruck | 61 KB, PDF
  • Is the consortium loan be entered as “Yes” in MACCs for each claim against borrowers´ note?

    Claims against borrowers´ notes that are not consortium loans must be entered in MACCs with “consortium loan – no”. Claims against borrowers´ notes that are contractually structured as a consortium loan must be entered in MACCs with “consortium loan – yes”. This choice requires to enter address information for all facility agents for these type of claim against borrowers´ notes. 

  • Should a quarterly binding assurance also be submitted for the TARGET-Contingency-Pool?

    Yes, the quarterly binding assurance is necessary if ECONS collateral was submitted to the TARGET-Contingency-Pool on the relevant reference date in the same way as the other pools available in MACCs. 

    There are two options for submitting the quarterly binding assurance:

    1. Submission of the document in paper form with original signatures of two authorised signatories to the Deutsche Bundesbank for all business transactions and sending the original document by post to the credit claims management of Deutsche Bundesbank or preferably
    2. Electronic transmission of the document with a qualified electronic signature (must meet the requirements of the eIDAS Regulation as amended) by two authorised signatories to the Deutsche Bundesbank for all business transactions and sending it by encrypted e-mail (S/MIME) to maccs@bundesbank.de. In this case, it is not necessary to send the document additionally by post.
  • Should the AnaCredit identifiers be recorded with or without blank spaces?

    The entry should be identical to that in AnaCredit. The observed agent identifier must not contain blank spaces, but it does not matter in MACCs if the contract and instrument identifiers do or not.

  • We are classified as a small reporting agent. Are we exempt from disclosing AnaCredit identifiers?

    The AnaCredit Regulation does not contain any reduced reporting obligations for those AnaCredit identifiers which must be reported to MACCs. All credit institutions are obligated to report these three AnaCredit identifiers. According to the AnaCredit requirements, however, if the total exposure to a debtor is under €25,000, these identifiers do not need to be reported.

  • What are the conditions for the usage of credit claims in case of a longer-term TARGET incident?

    To use credit claims for a longer-term TARGET incident, you have to open a specific additional collateral account. In addition, a specific general declaration on the assignment of credit claims for this collateral purpose must be submitted on the Deutsche Bundesbank's form number 5501‑2. The form for the specific assignment declaration can be downloaded in the area “customer information” in the section “Forms”. Before sending the specific assignment declaration, we recommend that you contact the support team credit claims.

    Further information

    • Other collateral positions
    • Forms
  • What does “facility agent” mean? Is the term facility agent a synonym for paying agent?

    A facility agent is a credit institution which takes on the administration of the loan, in particular the collection and transmission of payments.

    In MACCs, the paying agent is listed as a facility agent for claims against borrowers‘ notes, and the lead arranger, paying agent and collateral trustees are listed as facility agents for consortium loans.

    The terms used above for the facility agents are not intended to be prescriptive. The contractual status of the party is what is relevant. Facility agents (collateral trustees, lead arrangers and collateral trustees) are called servicers in AnaCredit, for example.

    See also Section V number 11(1) footnote 12 of our General Terms and Conditions.

  • What is meant by a “pool” in MACCs?

    In MACCs, a so-called “pool” (with pool ID, pool class and collateral account) is assigned to a rating source selected by the participant (ICAS, IRB , etc.). One purpose of the pool is to book transactions to the specified pool (additional)collateral account and, if necessary, to separate stocks of credit claims.

    In principle, one monetary policy pool will be available for each participant. Furthermore, technical preparations have been made for the use of two additional pools (ACC, TARGET-Contingency) in MACCs.

    A decision to set up additional monetary policy pools and/or further pool classes will be taken by the ECB.

  • What is meant by the regulation in the Terms and Conditions which states that the Bank must be informed promptly of any changes to credit claims (e.g. repayments, partial repayments, maturity)?

    “Promptly” means that these changes must be entered in the form of an update in MACCs no later than within the course of the next business day.

  • What is the difference between PSE1- and PSE2-debtor?

    “PSE” stands for “public sector entities” and refers to public sector bodies within the meaning of the Capital Requirements Regulation (CRR). A PSE1-debtor is usually a government entity, e.g. a municipality, city, federal state, etc. 

    A PSE2-debtor can be a non-financial corporation owned by a government entity with a public legal form, e.g. a public-law institution or corporation. Classification as a PSE2-debtor is made on a case-by-case basis.

    If PSE-debtors do not have their own ECAI rating, the option exists of applying a derived ECAI rating for these debtors pursuant to No 4(5) of the Special terms and conditions for assessing the credit quality of assets that are not published by the ECB in the list of eligible marketable assets pursuant to Section V subsection 3(1) of the General Terms and Conditions of the Deutsche Bundesbank: Creditworthiness conditions (Besondere Bedingungen für die Bonitätsbeurteilung von Sicherheiten, die nicht von der EZB im Sicherheitenverzeichnis nach Abschn. V Nr. 3 (1) Allgemeine Geschäftsbedingungen der Deutschen Bundesbank veröffentlicht sind: Bonitäts-Bedingungen). Classification in the relevant PSE category forms the basis for deriving the rating.

  • When entering data for the lead arranger, is it always necessary to also enter the details of the paying agent even when they are identical?

    The data must be entered where this is required by contract. If, for example, the lead arranger takes on the role of paying agent, their address must be entered for both the lead arranger and the paying agent. This also applies to all facility agents for a consortium loan.

  • When entering the addresses of facility agents, is the address entered in the commercial register sufficient, or must the address be as accurate as possible?

    As a matter of policy, up-to-date information must be submitted for every credit claim, including current addresses for facility agents. Compliance with our General Terms and Conditions can be verified only if the information submitted is up-to-date. We expect therefore the current business address of each facility agent according to the commercial register. This means that, where changes are made during the life of the loan, the contracting parties’ address information must be updated by MACCs participants. If other address details are available, e.g. the responsible department in the company, this must also be entered, this makes the postal delivery easier. The names of the employees should not be entered.

  • When is a guarantor relevant? What is the procedure for filing in each case?

    A contractually detained guarantor is referred to as relevant if the principal debtor of the credit claim does not have its own eligible rating and the rating of the guarantor is to be used.

    Before submitting a credit claim with a relevant guarantor, it is essential to contact the support team credit claims, as the Bundesbank must examine the credit agreement, the guarantee declaration and any legal opinion that may be required before using the guarantee.

    Information on the fulfillment of the credit claim by co-obligated parties, e.g. by means of a guarantee, can be found in No. 16 of the Bonitäts-Bedingungen. 

    Further information

    in German only

    • Bonitäts-Bedingungen
      06.05.2024 | 380 KB, PDF
  • When submitting a new credit claim, under what circumstances should the consortium loan checkbox be activated by selecting “yes”?

    The consortium loan checkbox is to be activated by selecting “yes” if the (eligible) credit claim to be submitted has its legal basis in a credit agreement under which several lenders grant one or more loans to one or more borrowers, which are administered by a consortium leader and/or under which payments are processed via a paying agent, but are not claims against borrowers’ notes. Each lender has a direct repayment claim against the borrower(s).

    In principle, loans extended by so-called external consortia in particular can meet this definition and fulfil the requirements for eligible collateral. Nevertheless, we cannot exclude that loans extended by internal consortia also meet the definition and may fulfil the eligibility criteria in individual cases due to the structure of the loan agreement.

    Sub-participations regularly do not fulfil the eligibility criteria. As a rule, they lack a legally independent credit claim that can be transferred free of third-party rights. The prohibition on submitting partial claims can also play a role in the case of sub-participations. Credit claims that fulfil the eligibility criteria (in particular, can be transferred free of third-party rights) and in which sub-participations exist thus usually do not have the above-mentioned characteristics of a consortium loan.

    Further information

    in German only

    • Information zur Zulässigkeit von Konsortialkrediten mit gepoolten Kreditsicherheiten
      15.04.2020 Vordruck | 61 KB, PDF
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