## Treatment of cash collateral

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### Background
- Guidance Note examines cash collateral transactions: agreements that entail the transfer of cash between two parties to secure credit exposures or other risks (paragraph 1).
- Typical occurrences: securities lending operations, clearing and settlement mechanisms, brokerage agreements, guarantees to governments, constitution of certain collateralized payables, court-ordered segregation in bankruptcy, and escrow accounts tied to real estate transactions (paragraph 1; paragraph 3; paragraph 4).
- Scope exclusions:
  - Excludes cash transfers that are part of settlement of transactions to acquire assets issued by third parties or to offset net liability positions in certain derivatives contracts, where no collateral is provided and no claim arises (paragraph 2).
  - Excludes segregation of cash assets in bankruptcy proceedings subject to court or creditor authorization where no market transaction occurs; statistical treatment of economic ownership in those cases is out of scope (paragraph 3).
- Existing standards and guidance:
  - BPM6 and 2008 SNA treat cash collateral associated with securities lending analogously to repurchase agreements, recording a deposit or loan liability for the party receiving cash and a corresponding asset for the party transferring cash (BPM6, paragraphs 5.52 and 5.53; 2008 SNA, paragraph 11.74) (paragraph 5).
  - Cash provided in gold swaps is treated analogously to repurchase agreements, as loans or deposits (BPM6, paragraph 5.55; 2008 SNA, paragraph 11.77) (paragraph 5).
  - BPM6 and 2008 SNA treat cash collateral in the context of financial derivatives as “repayable margins”; classification depends on whether claims are included in monetary aggregates: deposits if included, otherwise either deposits or other accounts receivable/payable depending on manual and compiler discretion (BPM6, paragraph 5.94 (a); 2008 SNA, paragraph 11.124) (paragraph 6).
  - ESA 2010 requires loans for “repayable margins” when claims are on units other than monetary financial institutions (ESA 2010, paragraph 5.136 (d)) (paragraph 7).
  - BPM6 and 2008 SNA indicate margin calls in cash in the repo market should be treated as loans (BPM6, paragraph 5.53; 2008 SNA, paragraph 11.75), but BPM6, paragraph 5.94 creates wording that could be interpreted as conflicting—some SNA/BPM text adaptations are needed to remove ambiguous messages (paragraph 8).
- Gap in guidance:
  - Standards do not provide guidance on generic pledging of cash collateral (e.g., collateralized guarantees from banking resolution regimes, deposit guarantee schemes, escrow accounts) (paragraph 9).
- Purpose of the Guidance Note:
  - To examine possibilities for a comprehensive and consistent (albeit not necessarily uniform) treatment of cash collateral in international standards, resolving partial and inconsistent guidance across manuals and within manuals (paragraph 10).

### Issues for discussion
- Core issue: classification of claims arising from transferring cash to secure any kind of credit exposure (paragraph 11).
- Distinction: cash payments to settle acquisitions of assets or to offset liabilities do not create claims on the counterparty and are excluded (paragraph 11).
- Question whether cash margin calls could be recorded as a reduction of the credit exposure they secure (paragraph 12).
  - Example: margin calls in cash under repo agreements might be seen as reducing the repo seller’s liability, but repo/securities lending agreements typically distinguish separate terms for cash collateral (e.g., differing interest rates) (paragraph 12).
- Current methodological guidance:
  - Some cash collateral claims are classified as deposits if corresponding liabilities are part of money definition—this suggests a general rule to treat cash collateral claims as deposits (paragraph 13).
  - Classification as deposits aligns with banks’ balance-sheet practice where short-term payables with similar characteristics are included in money definition and classified as deposits; ESA 2010, paragraph 5.118 is a strong requirement in that direction (paragraph 13).
  - Recommendation to amend wording in BPM6, paragraph 5.53 and 2008 SNA, paragraph 11.75 to avoid interpretation that repo margin calls are loans in all cases (paragraph 13).
- Lack of uniform guidance when liabilities are not in monetary aggregates:
  - Securities lending with cash collateral and repo margin calls currently aligned to loans (BPM6, paragraph 5.53; 2008 SNA, paragraph 11.75), but repayable margins in derivatives are treated differently across manuals (BPM6: other accounts receivable/payable; 2008 SNA: deposits or other accounts receivable/payable at compiler discretion; ESA 2010: loans) (paragraph 14).
- Guidance Note considers three options for instrument classification of claims arising from cash transfers that secure risk exposures where liabilities are not in money aggregates; collateral agreements that lead to liabilities of deposit-taking corporations are excluded because such liabilities are classified as deposits in all cases (paragraph 15).

### Option 1: Other accounts receivable/payable
- Current treatment in BPM6 and 2008 SNA; would require minimum wording changes though 2008 SNA definition of other accounts payable/receivable would need alteration (paragraph 16).
- Rationale:
  - Loans and deposits should apply to transactions with clear intention to raise or place funds; transactions here are motivated by securing risk exposures (paragraph 16).
  - Relevant textual support: BPM6, paragraph 5.51 and 2008 SNA, paragraph 11.72 indicate in loan transactions “a creditor lends funds directly to a debtor” (paragraph 16).
- Interaction with securities lending:
  - Securities lending with cash collateral would likely still be treated as loans given repos and securities lending are substitutes (paragraph 17).
- Implementation steps:
  - Resolve drafting conflict on repo margin calls (BPM6, paragraph 5.53 vs BPM6, paragraph 5.94 and 2008 SNA, paragraph 11.75), extend treatment to generic cash collateral transactions, and modify instrument definition of other accounts (paragraph 18).

### Option 2: Loans
- Characterization:
  - Claims associated with cash payments made to secure risk exposures are aligned with loan features in BPM6, paragraph 5.51 and 2008 SNA, paragraph 11.72 (provision of funds with absence of negotiability), implying purpose is largely irrelevant (paragraph 19).
- Rationale emphasizing economic effect over economic purpose:
  - Mirrors treatment that disregards purpose for securities lending with cash collateral and repos; repo interest (rebate) versus money market rates used to assess funding versus security demand forces (paragraphs 20–21).
  - Dealers and clearing houses often use cash collateral as funding or borrowing device; classifying claims as loans can be warranted (paragraph 20).
  - Margin calls respond to the same economic forces as initial repo/securities lending terms—maintaining equilibrium in value between funds and pledged assets (paragraph 21).
- Arguments against Option 1 under this view:
  - Other accounts receivable/payable are typically linked to timing differences between ownership changes and payments; cash collateral flows more naturally fit loan characterization and would require definitional changes to classify as other accounts (paragraph 22).
- Role of interest payments:
  - Cash collateral terms frequently include interest payments to the party constituting the deposit; existence of regular cash interest payments could support classification as loans (paragraph 23).
  - 2008 SNA, paragraph 17.236 suggests “there should be no interest arising on other accounts receivable and payable since the amounts outstanding that give rise to interest payments should be classified as loans,” implying assets with regular interest payments should be loans; recommendation to examine and clarify links between periodic interest payments and classification (paragraph 23).
- Relation to deposits:
  - Loans versus deposits distinction: Option 2 aligns with possible convention in BPM6, paragraph 5.40 (when one party is a deposit-taking corporation and the other is not, classify asset position of deposit-taking corporation as a loan) and would extend such convention as compulsory for cash-collateral claims on non deposit-taking corporations (paragraph 24).
  - Delineation between loans and deposits not purely sector-based because central governments can have deposit liabilities (paragraph 24).
- Implementation implications:
  - Would require changing handbooks to include generic provisions on cash collateral and change treatment of “repayable margins” in derivatives (BPM6, paragraph 5.94a; 2008 SNA, paragraph 11.124) to prescribe classification of arising claims as loans when claim is not part of money aggregates (paragraph 25).
  - Pros: Eliminates direct conflicts across manuals and addresses conceptual discrepancies in nature of claims (paragraph 25).
  - Cons: May not reflect intention of parties (no intention to fund) and could conflict with monetary aggregate statistics objectives (paragraph 25).

### Option 3: Deposits (recommended)
- Recommendation and outcome:
  - Option 3 is recommended (paragraphs 35–36, 38–39).
  - Recommendation: classify cash-collateral related liabilities as deposits (AF.2), rather than as loans (AF.4) or other payables (AF.8), except for securities lending with cash collateral which would be treated as loans (paragraphs 39, 34).
  - Create a new instrument subcategory (AF.X8) under AF.4, AF.8, or AF.2 (depending on the first-digit level decision) to cover margins and cash collateral, allowing separate analytical identification (paragraphs 32–33).
- Rationale and technical assessment:
  - Technical assessment concluded features of claims arising from pledging cash collateral align with those of deposits in the standards: they are non-negotiable claims represented by evidence of deposits (the Collateral Arrangement Agreement, CAA) (paragraphs 28, 36).
  - Definition of deposits in paragraph 4.29 of the Monetary and Financial Statistics Manual and Compilation Guide (MFSMCG) allows debtors other than deposit-taking corporations (central government) to incur deposit liabilities (paragraph 36).
  - Classification as loans (Option 2) is not appropriate because the funding intention central to the loan definition is absent; the purpose of cash placements is securing risk exposures rather than lending funds (paragraph 37).
  - Classification as other receivable/payable (Option 1) is not appropriate because:
    - CAAs provide evidence of deposits (paragraph 38).
    - The claims are not linked to timing differences between acquisition of assets/products and associated payments, a common feature of other accounts receivable/payable (paragraph 38).
- Practical implications and market-practice considerations:
  - Making instrument-class distinctions based on debtor sector (as in Options 1 and 2) could be highly distortive given market practices, e.g., when two parties maintain margining requirements on various contracts it would be difficult to justify different classifications for economically similar claims (paragraph 27).
  - Sector-based distinctions would prevent netting across instruments and could inflate balance sheets; allowing netting of bilateral margining obligations on OTC derivatives between the same parties in national accounts and balance of payments could prevent inflating balance sheets (paragraph 27).
  - The CAA is seen as representing the “evidence of deposit” required in 2008 SNA, paragraph 11.59, and BPM6, paragraph 5.39 (paragraph 28).
  - One feature distinguishing deposits from loans is the depositor’s initiative to recuperate funds by stopping the underlying action that requires depositing; creditor initiative is more characteristic of loans (paragraph 29).
- Scope, exceptions, and special cases:
  - Securities lending with cash collateral, repos, and associated margin calls would be considered separately and treated as loans (consistent with the standards) because the funding purpose is more prominent and equivalent to repos (paragraphs 30, 39).
  - Proposal allows considering exceptions for units not commonly seen as issuing deposits (in particular households); consultation responses varied: no exemption, a limited number, or very limited exclusions (perhaps limited to households) were suggested (paragraphs 30, 40).
  - Option 3 does not necessarily overrule compilers’ choice to follow BPM6, paragraph 5.40; it is recognized that the recommendation may appear to conflict with common associations of deposits to monetary aggregates and with ESA 2010 paragraph 5.79, but 2008 SNA, MFSMCG, and even ESA 2010 allow deposit liabilities for debtors other than deposit-taking corporations (paragraphs 41–41).
- Implementation requirements and effects on standards:
  - Implementing Option 3 would require changing current provisions regarding margins in financial derivatives and introducing standards on generic cash collateral obligations; these changes would eliminate direct and indirect inconsistencies similar to Option 2 (paragraph 31).
  - The new sub-instrument subcategory (AF.X8) would permit analysts to identify and treat margins and cash collateral separately for analytical purposes, though it would increase compilation burden (paragraphs 32–33).
  - Securities lending with cash collateral would be excluded from the AF.X8 sub-classification and treated in standard second-digit categories as loans/deposits as appropriate (paragraph 34).

### Questions for discussion
- Do you agree with Option 3 (classification as deposits of all cash-collateral related liabilities, including for units whose liabilities are usually not included in the monetary aggregates)? If rejecting Option 3, indicate a preference for Option 1 (other accounts receivable/payable) or Option 2 (loans) (Question 1).
- If Option 3 is supported, should exceptions be allowed for liabilities of certain institutional units (e.g., financial auxiliaries, non-financial corporations, households) so they could be treated as loans or other accounts payable? If yes, in which cases? (Question 2).
- Do you agree with proposing a new sub-instrument category (e.g., within deposits) to cover cash collateral claims? (Question 3).

*Source: Guidance Note — Treatment of cash collateral (FITT).*

### SECTION I: THE ISSUE

### SECTION I: THE ISSUE

### BACKGROUND

- The Guidance Note examines the treatment of cash collateral transactions: agreements that entail the transfer of cash between two parties to secure credit exposures or other risks (paragraph 1).
- Cash collateral transactions occur in securities lending operations, clearing and settlement mechanisms, brokerage agreements, guarantees to governments, constitution of certain collateralized payables, court-ordered segregation in bankruptcy, and escrow accounts tied to real estate transactions (paragraph 1; paragraph 3; paragraph 4).
- Scope exclusions:
  - Excludes cash transfers that are part of settlement of transactions to acquire assets issued by third parties or to offset net liability positions in certain derivatives contracts, where no collateral is provided and no claim arises (paragraph 2).
  - Excludes segregation of cash assets in bankruptcy proceedings subject to court or creditor authorization where no market transaction occurs; statistical treatment of economic ownership in those cases is out of scope (paragraph 3).
- Existing standards and guidance:
  - BPM6 and 2008 SNA treat cash collateral associated with securities lending analogously to repurchase agreements, recording a deposit or loan liability for the party receiving cash and a corresponding asset for the party transferring cash (BPM6, paragraphs 5.52 and 5.53; 2008 SNA, paragraph 11.74; paragraph 5).
  - Cash provided in gold swaps is treated analogously to repurchase agreements, as loans or deposits (BPM6, paragraph 5.55; 2008 SNA, paragraph 11.77) (paragraph 5).
  - BPM6 and 2008 SNA treat cash collateral in the context of financial derivatives as “repayable margins”; classification depends on whether claims are included in monetary aggregates: deposits if included, otherwise either deposits or other accounts receivable/payable depending on manual and compiler discretion (BPM6, paragraph 5.94 (a); 2008 SNA, paragraph 11.124) (paragraph 6).
  - ESA 2010 departs from SNA by requiring loans for “repayable margins” when claims are on units other than monetary financial institutions (ESA 2010, paragraph 5.136 (d)) (paragraph 7).
  - BPM6 and 2008 SNA indicate margin calls in cash in the repo market should be treated as loans (BPM6, paragraph 5.53; 2008 SNA, paragraph 11.75), but BPM6, paragraph 5.94 creates wording that could be interpreted as conflicting—some SNA/BPM text adaptations are needed to remove ambiguous messages (paragraph 8).
- Gap in guidance:
  - Standards do not provide guidance on generic pledging of cash collateral (e.g., collateralized guarantees from banking resolution regimes, deposit guarantee schemes, escrow accounts) (paragraph 9).
- Purpose of the Guidance Note:
  - To examine possibilities for a comprehensive and consistent (albeit not necessarily uniform) treatment of cash collateral in international standards, resolving partial and inconsistent guidance across manuals and within manuals (paragraph 10).

### ISSUES FOR DISCUSSION

- Core issue: classification of claims arising from transferring cash to secure any kind of credit exposure (paragraph 11).
- Distinction: cash payments to settle acquisitions of assets or to offset liabilities do not create claims on the counterparty and are excluded (paragraph 11).
- Question whether cash margin calls could be recorded as a reduction of the credit exposure they secure (paragraph 12).
  - Example: margin calls in cash under repo agreements might be seen as reducing the repo seller’s liability, but repo/securities lending agreements typically distinguish separate terms for cash collateral (e.g., differing interest rates) (paragraph 12).
- Current methodological guidance:
  - Some cash collateral claims are classified as deposits if corresponding liabilities are part of money definition—this suggests a general rule to treat cash collateral claims as deposits (paragraph 13).
  - Classification as deposits aligns with banks’ balance-sheet practice where short-term payables with similar characteristics are included in money definition and classified as deposits; ESA 2010, paragraph 5.118 is a strong requirement in that direction (paragraph 13).
  - Recommendation to amend wording in BPM6, paragraph 5.53 and 2008 SNA, paragraph 11.75 to avoid interpretation that repo margin calls are loans in all cases (paragraph 13).
- Lack of uniform guidance when liabilities are not in monetary aggregates:
  - Securities lending with cash collateral and repo margin calls currently aligned to loans (BPM6, paragraph 5.53; 2008 SNA, paragraph 11.75), but repayable margins in derivatives are treated differently across manuals (BPM6: other accounts receivable/payable; 2008 SNA: deposits or other accounts receivable/payable at compiler discretion; ESA 2010: loans) (paragraph 14).
- The Guidance Note considers three options for instrument classification of claims arising from cash transfers that secure risk exposures where liabilities are not in money aggregates; collateral agreements that lead to liabilities of deposit-taking corporations are excluded because such liabilities are classified as deposits in all cases (paragraph 15).

### OPTION 1: OTHER ACCOUNTS RECEIVABLE/PAYABLE

- Current treatment in BPM6 and 2008 SNA; would require minimum wording changes though 2008 SNA definition of other accounts payable/receivable would need alteration (paragraph 16).
- Rationale:
  - Loans and deposits should apply to transactions with clear intention to raise or place funds; transactions here are motivated by securing risk exposures (paragraph 16).
  - Relevant textual support: BPM6, paragraph 5.51 and 2008 SNA, paragraph 11.72 indicate in loan transactions “a creditor lends funds directly to a debtor” (paragraph 16).
- Interaction with securities lending:
  - Securities lending with cash collateral would likely still be treated as loans given repos and securities lending are substitutes (paragraph 17).
- Implementation steps:
  - Resolve drafting conflict on repo margin calls (BPM6, paragraph 5.53 vs BPM6, paragraph 5.94 and 2008 SNA, paragraph 11.75), extend treatment to generic cash collateral transactions, and modify instrument definition of other accounts (paragraph 18).

### OPTION 2: LOANS

- Characterization:
  - Claims associated with cash payments made to secure risk exposures are aligned with loan features in BPM6, paragraph 5.51 and 2008 SNA, paragraph 11.72 (provision of funds with absence of negotiability), implying purpose is largely irrelevant (paragraph 19).
- Rationale emphasizing economic effect over economic purpose:
  - Mirrors treatment that disregards purpose for securities lending with cash collateral and repos; repo interest (rebate) versus money market rates used to assess funding versus security demand forces (paragraphs 20–21).
  - Dealers and clearing houses often use cash collateral as funding or borrowing device; classifying claims as loans can be warranted (paragraph 20).
  - Margin calls respond to the same economic forces as initial repo/securities lending terms—maintaining equilibrium in value between funds and pledged assets (paragraph 21).
- Arguments against Option 1 under this view:
  - Other accounts receivable/payable are typically linked to timing differences between ownership changes and payments; cash collateral flows more naturally fit loan characterization and would require definitional changes to classify as other accounts (paragraph 22).
- Role of interest payments:
  - Cash collateral terms frequently include interest payments to the party constituting the deposit; existence of regular cash interest payments could support classification as loans (paragraph 23).
  - 2008 SNA, paragraph 17.236 suggests “there should be no interest arising on other accounts receivable and payable since the amounts outstanding that give rise to interest payments should be classified as loans,” implying assets with regular interest payments should be loans; recommendation to examine and clarify links between periodic interest payments and classification (paragraph 23).
- Relation to deposits:
  - Loans versus deposits distinction: Option 2 aligns with possible convention in BPM6, paragraph 5.40 (when one party is a deposit-taking corporation and the other is not, classify asset position of deposit-taking corporation as a loan) and would extend such convention as compulsory for cash-collateral claims on non deposit-taking corporations (paragraph 24).
  - Delineation between loans and deposits not purely sector-based because central governments can have deposit liabilities (paragraph 24).
- Implementation implications:
  - Would require changing handbooks to include generic provisions on cash collateral and change treatment of “repayable margins” in derivatives (BPM6, paragraph 5.94a; 2008 SNA, paragraph 11.124) to prescribe classification of arising claims as loans when claim is not part of money aggregates (paragraph 25).
  - Pros: Eliminates direct conflicts across manuals and addresses conceptual discrepancies in nature of claims (paragraph 25).
  - Cons: May not reflect intention of parties (no intention to fund) and could conflict with monetary aggregate statistics objectives (paragraph 25).

### OPTION 3: DEPOSITS

- (Content for Option 3 begins after the provided text and is not included in the supplied content.)

*Prepared by the Guidance Note authors as summarized from SECTION I: THE ISSUE of the Guidance Note.*

### 26.      The proponents of this option do not see necessary to make a distinction of instrument

### Treatment of cash collateral (Option 3 recommended)

### Recommendation and outcome
- Option 3 is recommended (paragraphs 35–36, 38–39).
- Recommendation: classify cash-collateral related liabilities as deposits (AF.2), rather than as loans (AF.4) or other payables (AF.8), except for securities lending with cash collateral which would be treated as loans (paragraphs 39, 34).
- Create a new instrument subcategory (AF.X8) under AF.4, AF.8, or AF.2 (depending on the first-digit level decision) to cover margins and cash collateral, allowing separate analytical identification (paragraphs 32–33).

### Rationale and technical assessment
- The technical assessment concluded that features of claims arising from pledging cash collateral align with those of deposits in the standards: they are non-negotiable claims represented by evidence of deposits (the Collateral Arrangement Agreement, CAA) (paragraphs 28, 36).
- The definition of deposits in paragraph 4.29 of the Monetary and Financial Statistics Manual and Compilation Guide (MFSMCG) allows debtors other than deposit-taking corporations (central government) to incur deposit liabilities (paragraph 36).
- Classification as loans (Option 2) is not appropriate because the funding intention central to the loan definition is absent; the purpose of cash placements is securing risk exposures rather than lending funds (paragraph 37).
- Classification as other receivable/payable (Option 1) is not appropriate because:
  - CAAs provide evidence of deposits (paragraph 38).
  - The claims are not linked to timing differences between acquisition of assets/products and associated payments, a common feature of other accounts receivable/payable (paragraph 38).

### Practical implications and market-practice considerations
- Making instrument-class distinctions based on debtor sector (as in Options 1 and 2) could be highly distortive given market practices, e.g., when two parties maintain margining requirements on various contracts it would be difficult to justify different classifications for economically similar claims (paragraph 27).
- Such sector-based distinctions would prevent netting across instruments and could inflate balance sheets; allowing netting of bilateral margining obligations on OTC derivatives between the same parties in national accounts and balance of payments could prevent inflating balance sheets (paragraph 27).
- The CAA is seen as representing the “evidence of deposit” required in 2008 SNA, paragraph 11.59, and BPM6, paragraph 5.39 (paragraph 28).
- One feature distinguishing deposits from loans is the depositor’s initiative to recuperate funds by stopping the underlying action that requires depositing; creditor initiative is more characteristic of loans (paragraph 29).

### Scope, exceptions, and special cases
- Securities lending with cash collateral, repos, and associated margin calls would be considered separately and treated as loans (consistent with the standards) because the funding purpose is more prominent and equivalent to repos (paragraphs 30, 39).
- The proposal allows considering exceptions for units not commonly seen as issuing deposits (in particular households), but consultation responses varied: no exemption, a limited number, or very limited exclusions (perhaps limited to households) were suggested (paragraphs 30, 40).
- Option 3 does not necessarily overrule compilers’ choice to follow BPM6, paragraph 5.40; it is recognized that the recommendation may appear to conflict with common associations of deposits to monetary aggregates and with ESA 2010 paragraph 5.79, but 2008 SNA, MFSMCG, and even ESA 2010 allow deposit liabilities for debtors other than deposit-taking corporations (paragraphs 41–41).

### Implementation requirements and effects on standards
- Implementing Option 3 would require changing current provisions regarding margins in financial derivatives and introducing standards on generic cash collateral obligations; these changes would eliminate direct and indirect inconsistencies similar to Option 2 (paragraph 31).
- The new sub-instrument subcategory (AF.X8) would permit analysts to identify and treat margins and cash collateral separately for analytical purposes, though it would increase compilation burden (paragraphs 32–33).
- Securities lending with cash collateral would be excluded from the AF.X8 sub-classification and treated in standard second-digit categories as loans/deposits as appropriate (paragraph 34).

### Questions for discussion (as posed in the Guidance Note)
- Do you agree with Option 3 (classification as deposits of all cash-collateral related liabilities, including for units whose liabilities are usually not included in the monetary aggregates)? If rejecting Option 3, indicate a preference for Option 1 (other accounts receivable/payable) or Option 2 (loans) (Questions 1).
- If Option 3 is supported, should exceptions be allowed for liabilities of certain institutional units (e.g., financial auxiliaries, non-financial corporations, households) so they could be treated as loans or other accounts payable? If yes, in which cases? (Question 2).
- Do you agree with proposing a new sub-instrument category (e.g., within deposits) to cover cash collateral claims? (Question 3).

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_Source: https://www.imf.org/-/media/files/data/statistics/bpm6/fitt/f10-treatment-of-cash-collateral.pdf_