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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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.
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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 or steel cabinet/vault.
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The application is made by signing and sending a declaration of assignment for this specific security purpose to the support team credit claims. In addition to participating in MACCs, opening or the existence of a specific additional collateral account is required.
Further information
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If a credit institution, e.g. a Landesbank, arranges a consortium loan and acts as the lead arranger, the address information of said credit institution must be entered.
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AnaCredit identifiers must be reported in MACCs for all forms of credit claims, including claims against borrowers‘ notes.
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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.
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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).
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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 permits to enter address information for all facility agents for these type of claim against borrowers´ notes. The rule in question in the MACCs user manual will be updated accordingly.
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Yes, the quarterly binding assurance is necessary if ECONS collateral was submitted to the TARGET-Contingency-Pool on the relevant reference date. A quarterly binding assurance, similar to the other collateral pools available in MACCs, is to be sent to the support team credit claims by post.
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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.
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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.
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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. 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
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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.
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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.
Initially, 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.
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“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.
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“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-deptor 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 (Besonderen 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.
In ExtraNet you can call up the list of public entities that exist in MACCs, if you have applied for the role “Info file PSE (file download)”.
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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.
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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.
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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
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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.