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.

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.

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.

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

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.

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).

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 types of claims against borrowers´ notes. 

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.

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.

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 less than €25,000, these identifiers do not need to be reported.

To use credit claims for a longer-term TARGET incident, you need an additional collateral account [similar to ECON pool in ECMS]. Use of the TARGET contingency pool (pool ID 201) requires a separate application. The application is made by signing a specific general declaration on the assignment of credit claims for this collateral purpose 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.

If you have any questions to open an additional collateral account, please contact the ECMS – National Service Desk.

The relevant date for the change in MACCs is the date on which the change occurs, but no later than within the course of the next business day.

A facility agent is a credit institution which takes over 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 paying agent, consortium manager and collateral trustees are listed as facility agents for consortium loans.

The above-mentioned terms for the facility agents are not to be taken literally. The contractual status of the party is what is relevant. Facility agents (paying agent, consortium manager 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.

In MACCs, a so-called “pool” (with pool ID, pool class and collateral account (analogue Counterparty Pool in ECMS)) serves to separate credit claim portfolios in accordance with the specifications of the Deutsche Bundesbank. Each pool of a domestic participant is assigned to a collateral account (analogue Counterparty Pool in ECMS). 

It is also possible to assign several pools to one collateral account (analogue to Counterparty Pool in ECMS). 

For each pool, one rating type can be assigned per country-sector combination for the valuation of stocks.

The Monetary Policy Utilisation Pool (Pool ID 101) is available to all domestic participants. 

Use of the TARGET contingency pool (Pool ID 201) requires a separate application to. If you wish to use non-marketable collateral for ECONS loans, please contact the support team credit claims. 

The temporary pool for additional credit claims, so-called ACC (Pool ID 401), and the ACC reserve pool (Pool ID 402) are available in MACCs. The introduction of an ACC framework is announced in a customer information notice. The use of ACC collateral must be applied for separately.

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

“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 Deutsche Bundesbank's General Terms and Conditions: 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.

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 (see Section V, No. (1) of the Deutsche Bundesbank´s Terms and Conditions) can also play a role in the case of sub-participations. A Credit claim that fulfils the eligibility criteria (in particular, can be transferred free of third-party rights) and in which (a) sub-participation(s) exist(s) can be – if it qualifies as an external consortium loan- submitted to MACCs.

The data must be entered where this is required by contract. If, for example, the lead arranger assumes 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 of a consortium loan.

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.

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”.

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