Depositor Compensation Scheme Consultation Document on the setting up of a Fast Payout Mechanism & Reform of Reporting Requirements 30/03/2012 Page | 1 Contents 1 Introduction .................................................................................................................................... 3 2 Current statutory obligations.......................................................................................................... 3 2.1 3 Electronic Information Transmission and Fast Payout System ....................................................... 4 3.1 SCV High-level Technical Architecture and Workflow ............................................................ 5 3.2 Required Information and Overview of the SCV Templates ................................................... 5 3.2.1 Template A ...................................................................................................................... 6 3.2.2 Template B ...................................................................................................................... 6 3.2.3 Template C ...................................................................................................................... 8 3.2.4 Templates D1 and D2 ...................................................................................................... 8 3.2.5 Codes............................................................................................................................... 8 3.2.6 Additional Notes ............................................................................................................. 9 3.3 Data Collection over a Secure Channel ................................................................................. 10 3.3.1 Access to the DCS SCV Hub ........................................................................................... 10 3.3.2 Directory tree ................................................................................................................ 10 3.4 4 Proposed arrangements under the Recast DGS Directive ...................................................... 4 Input File Format................................................................................................................... 11 3.4.1 Common features ......................................................................................................... 11 3.4.2 Format and Structure of CSV Files ................................................................................ 12 3.5 Confidentiality ....................................................................................................................... 13 3.6 Testing ................................................................................................................................... 13 Revision of Schedule LD7 .............................................................................................................. 14 4.1 Annexes ................................................................................................................................. 14 30/03/2012 Page | 2 1 Introduction The Management Committee of the Depositor Compensation Scheme (DCS) is planning to reform a number of reporting requirements by credit institutions in terms of the DCS regulations. The reform has two objectives, namely to guarantee a fast compensation payout to all eligible depositors within the period stipulated by the regulations in the event of a credit institution failure as well as to enable the DCS to have access to consolidated data about eligible and insured/covered deposits which is both timely and reliable. In respect of the first objective, the Management Committee intends to develop an electronic system to receive and process specific depositors’ data sent by credit institutions to the Scheme. As to the second objective, the Management Committee is reviewing the statutory return ‘Schedule LD7’, which credit institutions submit periodically to the MFSA. The purpose of this document is for the Management Committee to engage with stakeholders on the various aspects relating to this reform in the light of the current legislative requirements. The information contained in this document is only intended for consultation purposes and does not purport to represent or prejudge the final position that the Management Committee will take in relation to the topics covered. Stakeholders are invited to send their views on any aspects of the reform as outlined in this document by 15 May 2012 to info@compensationschemes.org.mt. Responses will be published on the Depositor Compensation Scheme’s website, unless a stakeholder requests that a submission remains confidential. 2 Current statutory obligations Regulation 13 of LN 369 of 2003 (DCS regulations) requires the competent authority to make a determination “…as soon as possible and in any event no later than five working days after first becoming satisfied that a credit institution has failed to repay deposits which are due and payable.” Sub-paragraph (3) of the same regulation specifies that “as soon as practicable after a determination is made, the competent authority shall inform the Management Committee in writing of such determination…” The determination will trigger a fast payout process to depositors of the affected credit institution. In order to further foster the DCS’ preparedness, the Management Committee is proposing that the Authority should give advance warning to the DCS of any impending processes that may lead to a determination. According to sub-paragraph 4 of Regulation 14 of LN 369 of 2003, “The Management Committee shall proceed to pay compensation for verified claims within twenty working days from the date of the determination given in terms of Regulation 13(1). This time limit includes the collection and transmission of the accurate data on depositors and deposits, which are necessary for the verification of claims”. The Competent Authority may, in wholly exceptional circumstances and in special cases, allow an extension of 10 working days on application by the Management Committee. 30/03/2012 Page | 3 Furthermore, sub-paragraph 6 of Regulation 14 requires credit institutions to ensure “that they have electronic information systems in place to the satisfaction of the Scheme to enable the Scheme to process claims for compensation by depositors and this at all times, whether or not a determination has been made under Regulation 13(1).” The current regulations stipulate that before payout, a depositor is required to apply to the Scheme for compensation. The Scheme may postpone payment until it is certain that the depositor is eligible to receive compensation. The Scheme may also make partial payments where, in the opinion of the Management Committee, circumstances so warrant. Sub-paragraph 19(1)(c) also requires the Scheme to deduct from the total liability of the credit institution “the amount of any liability of the depositor to that credit institution in respect of which a right of set-off against the said deposit existed immediately before the notice of determination issued in terms of Regulation 13 or in respect of which such a right would have existed had the said deposit been repayable on demand and such liability fallen due immediately before the issue of such a notice of determination.” Regulation 26 empowers the Management Committee to request information from credit institutions “…which the Management Committee may consider relevant for the proper administration of the Scheme.” Any information which a credit institution communicates to the Management Committee “…as may be required to enable the Management Committee and its officers or agents to perform their duties and carry out their functions under these regulations” shall not be in breach of the duty of confidentiality in terms of Regulation 27 of the same regulations. 2.1 Proposed arrangements under the Recast DGS Directive Although discussions on the proposal for a re-cast Directive on Deposit Guarantee Schemes (July 2010) are on-going, there are certain aspects on which a broad consensus has already been reached or likely to have been reached. For the purposes of the objectives for which this consultation has been drawn up, it is likely that the payout period under a future directive is likely to remain 20 working days for a yet undefined number of years in order to allow the Schemes to setup appropriate systems to manage the incidence of credit institution failures and the processing of compensation payments. Thereafter, a shortened payout period will most likely come into force. Moreover, a peer-review system is planned to be established in order to ensure that all Schemes have the appropriate systems in place to discharge their duties under the Directive. In addition, the recast Directive provides for all currencies to be covered up to EUR 100,000 (and equivalent in any non-euro currency). Moreover, all depositors will be eligible to receive compensation (except for a few exceptions) and set-off will no longer be applied on amounts not yet fallen due. Depositors will not be required to apply to receive compensation, which essentially requires credit institutions to have their data updated in real-time and have this readily available for transmission to the Scheme for processing purposes. 3 Electronic Information Transmission and Fast Payout System The key element of the reform is the creation of an electronic process by the Scheme which provides for an efficient and secure transmission of customers’ information by a deposit taking credit institution to the Scheme. For the purposes of the Scheme, a customer means any depositor of a 30/03/2012 Page | 4 credit institution, excluding those persons listed in the First Schedule of the Scheme’s Regulations dated 21st November 2003, who is eligible to receive compensation in terms of the Schemes’ Regulations. Each credit institution is responsible to develop/modify its internal IT systems to enable the generation of the required data files with specific fields and codes that map the information required on every eligible (certain and potential) depositor of the credit institution. For the purposes of the Scheme, the information reported by a credit institution on its customers shall be called Single Customer View (SCV) information and this may be composed of 1 or more data files as explained further below. Upon determination of a credit institution’s failure under Regulation 13 of the Scheme, the failed credit institution will be obliged to transmit the SCV data to the Scheme by uploading its SCV file/s into the Scheme’s electronic system within a maximum of three working days. 3.1 SCV High-level Technical Architecture and Workflow The solution will namely consist of the main components and processes identified in the figure presented below. 3.2 Required Information and Overview of the SCV Templates Deposit taking credit institutions have already agreed, under the auspices of the Malta Bankers’ Association (MBA), customer data sets that the DCS would require to receive from a failed credit institution in order to process its compensation obligations. However, new research and analysis conducted since then revealed that the information to be reported needs to be enhanced to ensure the timely and efficient processing of compensation payments to every eligible depositor of a failed credit institution. 30/03/2012 Page | 5 To enable the automated processing of customer’s data, the DCS has prepared standard templates containing the SCV information which credit institutions will be required to report on each customer. For ease of reporting and processing of compensation payments, each template shall contain a specific set of data, which is relevant for every particular client account scenario. When there is a deemed determination, the failed credit institution will be required to compile the following templates: Template Template A Template B Template C Template D1 Template D2 Description Customer details Details of Account(s) Claims against customer (With a right of set-off) Aggregation details Compensation details A copy of each template is being attached to this document, such that every member of the Scheme will ensure that it is in a position to provide all the necessary details as required by the Scheme. Credit institutions are invited to review the contents, including the fields, codes and descriptions contained in the templates and send any comments to the Scheme as mentioned further above in this document A description of the SCV templates is briefly outlined in the following sections and a soft-copy of each template is being attached in Section 3.4.2.2 3.2.1 Template A The identification and address details of a customer are to be included in this template. In the event of joint accounts, each joint account holder shall be treated as a separate customer. Moreover, where a customer is holding an account on behalf of other persons under a contractual agreement (such as a deed of trust, nominee agreement etc.), the details of such customer should also be reported in the generated file. The SCV Identifier (SCV Id) should be unique for each and every customer. In cases where a particular customer features in more than 1 of the reported templates, then the respective SCV Identifier (SCV Id) should link to this field to enable the required relationships/linkages. 3.2.2 Template B This template will contain the core information required on each account for every customer, which will thereon form the basis for the compensation payable to the customer. Specific fields are included in this table for the reporting of the designated currency of each account. This will enable the compensation payment to be processed in the designated currency as per Regulation 17 of the Scheme’s Regulations. Template B is divided into three classes of account details so that the Scheme can determine the appropriate action required on the respective account balance. The three classes are: Class 1 – This class comprises the accounts which are “fit for straight-through payout” and will include the current and savings accounts in which the holder is the underlying beneficiary. Joint 30/03/2012 Page | 6 accounts are included under this class, the amount of which shall reflect the joint account holder’s share in line with Regulation 23 of the Scheme. Class 2 – This includes “beneficiary accounts”. For the purposes of the SCV requirements, the owner of a beneficiary account holds the account on behalf of underlying clients by way of a contractual arrangement, such as a deed of trust etc. Beneficiary accounts are deemed “not fit for straightthrough payout” because they will require the Scheme to obtain more information, such as the identification of each beneficiary, before payments of the respective compensations are effected. As a consequence, the failed credit institution will also be required to provide the Scheme within a period of time agreed with the Management Committee, with a list of the SCV identification numbers and account numbers of all beneficiary accounts reported in Template B, together with the following data on each respective beneficiary: Name, ID Number, Contact Details (Mail Address, Email Address, Telephone Number), Beneficiary’s Share on the Account. Class 3 – This includes all other accounts which are “not fit for straight-through payout”. Such account class will encompass fixed term deposit accounts or any accounts which are blocked because of any legal impediment. The compensation regarding fixed term deposit accounts will be flagged for payment on the actual maturity of each deposit. In the case of any account with a legal impediment, the Management Committee may decide to delay compensation payment until the outcome of a legal resolution is finalised. Any information available by the failed credit institution concerning this account status, which may be of relevance for the Scheme to determine whether and when compensation payment may be effected (E.g. The End Date of a Minor Status, Garnishee Order, Pledge File Number etc…), must be included in the “Account Status Information” column to be reported with Template B for Case 3 only. In the event of a current or savings account which is partially blocked, the blocked amount should be reported as a Class 1 record on its own. The unblocked amount must be reported as a separate Class 3 record in the same Template. In the case of a fixed term account which is partially blocked, the blocked and unblocked amounts must also be reported in separate Class 3 records within Template B and marked by the relevant account status codes as follows: Blocked amount: E.g. “BLOCK” is the status for a blocked account Unblocked amount: E.g. “TERM” is the status for an account that is flagged for payment on maturity of deposit Note: Refer to the Section 3.2.5 for a list of different possible account statuses. Regarding accounts which are recorded in Template B, the failed credit institution will also be obliged to provide to the Scheme with any further information available to it, which may assist the Scheme to determine the way forward. As mentioned earlier, and also in view of creating a robust SCV database, the details of every account held by a customer must be recorded separately in the respective classes (Class 1; Class 2 and Class 3) of the SCV. For example, if a customer holds different accounts in the same account 30/03/2012 Page | 7 class (E.g. a current account and a savings account in Class 1) the details of both accounts must feature in separate records of Template B. Furthermore, each record will be numbered for identification purposes. The segregation of each customer account is intended to assist the Scheme in its control functions and in addressing any queries from eligible depositors. 3.2.3 Template C This template shall contain the details of any legal claims against a customer in respect of which, the failed credit institution has a right of set off as per Regulation 19 of the Scheme’s Regulations. The table will include fields for the reporting of the debit balance and accrued interest on any loan or overdrawn account of the customer as well as for the reporting of the type of customer liability, such as “house loan”, “overdraft” etc... To enable the automated processing of data, the “gross balance” of any liability account (including the balance and accrued interest) with a right of set-off, is identified by code “CLAIM1”. Different liability accounts of a customer should also be reported as separate records. 3.2.4 Templates D1 and D2 Templates D1 and D2 contain the aggregate balances of the accounts which are fit for straightthrough payout and the other accounts which are not fit for straight-through payout (not including “beneficiary accounts”). No consolidation of data is required in the case of beneficiary accounts because of the reasons explained earlier. Where an eligible customer has more than one account per class of account details (Class 1 or Class 3), the aggregate balances in Template D1 will reflect the total of his separate account balances for each class and for each currency denomination respectively. The designated currency and the exchange rate should be included in the aggregation table to ensure compliance with the statutory compensation limit of €100,000 and to enable payment of compensations in the designated currency as and where appropriate. The compensation table (Table D2) will include the “net position” of each customer in EUR or EUR equivalent, after deducting any claims over which the failed credit institution has a right of set-off against the customer. The compensation due to a customer shall be based on the customer’s net position. Where a customer holds accounts in different currencies and his aggregate deposit balance exceeds the maximum compensation limit, the criteria to be used for the choice of the payment currencies shall be as follows: The default payment currency will be EUR The residual balance will be paid in the currency of the account which has the highest (EUR equivalent) amount. 3.2.5 Codes To enable easier automation of data processing, the following specific codes will be required for the identification of the account type, account holder type and/or the account status: Field Code Description Account Type Current Saving Term Current account Savings account Fixed Term Deposit account 30/03/2012 Page | 8 Account Holder Indicator 001 002/3/etc… 101 102 201 202 Account Status Code FSTP TERM NOM CLIENT TRUST OTHER FRAUD LAUND DORM BLOCK PLEDGE MINOR DISP GONEA DEC Single account holder One of two joint account holders / one of three joint account holders / etc… Beneficiary account – Current or Savings account Beneficiary account – Fixed Term Deposit account Other Account Not Fit for Straight-Through Payout – Current or Savings account Other Account Not Fit for Straight-Through Payout – Fixed Term Deposit account Fit for straight-through payout Account flagged for payment on maturity of deposit Nominee account Client account Trust account Other beneficiary account Fraud risk Money laundering suspicion Dormant account Blocked account Pledged account Minor account Legal dispute or competing claim on the account Account holder gone away Deceased customer 3.2.6 Additional Notes The above-mentioned information requirements are essential to guarantee an efficient and transparent administration of compensation payments in the event of a credit institution failure. The Management Committee is committed to ensure that every credit institution would have the necessary resources and systems in place to be able to provide the information to the Scheme in line with the above-mentioned requirements. Since it is likely that not all deposits will be fit for straight through payout, it will be necessary for the Scheme to retain a channel of communication with the credit institution in respect of which a determination has been made. Consequently the DCS is recommending that all credit institutions should nominate an official in possession of the necessary authority and with access to the credit institution’s records in order to respond to the information requirements of the DCS. The SCV requirements as mentioned in this consultation document are based on the current DCS regulations. In the meantime, the Management Committee is following developments in the recast Directive, which may require amendments in future in the local legislation. The Management Committee will also consider recommendations from stakeholders which whilst simplifying the fast payout process do not jeopardise the interests of depositors or breach the Directive. For this purpose the Management would welcome the comments of stakeholders to the following measures: 30/03/2012 Page | 9 3.3 The compensation regarding fixed term deposits to be payable within the prescribed compensation period instead of on maturity of the deposit All compensation payments to be effected in Euro only The elimination of the right of set-off against a customer in the calculation of the customer’s compensation Data Collection over a Secure Channel The DCS through the SCV system that is being proposed here will be providing a channel for the collection of data by allowing credit institutions to upload the required files by interfacing with the DCS SCV hub through standard communication protocols. The DCS SCV hub is a central infrastructure on which all credit institutions can connect using their own credentials (See Section 3.3.1) and upload files in order to exchange them with the DCS SCV system. Each credit institution will have its own area on a server hosted by the Malta Financial Services Authority on behalf of the Depository Compensation Scheme that will be configured in a firewallprotected environment. This area will contain all files the entity has sent. Credit institutions will connect to the hub using either FTPs1 or sFTP2 protocols. The manual exchange system using sFTP or FTPs can also be automated. This automation is the responsibility of the credit institutions and it can be done by using scripting languages. The credit institutions are responsible for acquiring and maintaining their own software to connect to the DCS SCV hub. Each credit institution decides the protocol and client to connect to the hub. This client software should be fully compatible with the relevant protocols. The DCS SCV hub supports the following protocols: Standard Protocol: FTP Security Protocol: SSL V3 and TLS V1; SSH2 and SFTP V3 3.3.1 Access to the DCS SCV Hub The access to the DCS SCV Hub is performed using credentials (username / password). These will be provided by the system administrator. An agreed set of credentials will be delivered for each credit institution providing data to the DCS. User access for any deposit taking credit institution shall be restricted to the SCV information of its credit institution only. The profiles to be provided to the system administrators and to the DCS management team shall enable these users to access all the information stored in the system. 3.3.2 Directory tree As already mentioned, each credit institution will have its own area on the server that can be accessed only by them. This area has the same directory structure for all entities. Whichever protocol is used to connect, the credit institutions will have access to the same area (credit institution area). 1 2 FTP over TLS/SSL (explicit encryption) SFTP using SSH2 (SSH File Transfer Protocol) 30/03/2012 Page | 10 A possible tentative directory structure in each area allocated to each and every credit institution may contain the following directories: Incoming Outgoing Rejected Archive / Incoming Archive / Outgoing The incoming directory will contain the files received/uploaded by the credit institution. The outgoing directory is the folder to be used by the DCS in circumstances when it requires exchanging files with a particular credit institution. Archive folders contain the files sent or received. Rejected files are not archived in the archive / outgoing directory. The rejected folder contains erroneous files, which have been sent and have been rejected by the HUB due to some kind of error. 3.4 Input File Format In order to simplify the automation of the SCV system that is being proposed here the DCS considers that one standard format should be applied and used by every credit institution for the transmission of the file/s holding the required information. This will also enable an acceptable level of harmonisation. The MBA has already expressed its opinion that simple file formats such as CSV Files are preferred. The Scheme will consider any feedback from the stakeholders on the file format and structure and any problems that may be envisaged in the generation of the electronic files and their transmission into the SCV system. The IT specifications and system design will be created following finalisation of the consultation phase. 3.4.1 Common features 3.4.1.1 Naming Convention The name of the SCV file/s must comply with the format below and only accepts Latin characters. [CreditInstitutionID]_ [TemplateID]_SCV_[SequenceNumber]_[Timestamp].csv Where: [CreditInstitutionId] is the unique ID of the credit institution uploading the files [TemplateID] is the name of the template on which this particular file is based [SequenceNumber] is a unique sequence number on 6 digits. This field is completed with 0 to fit to 6 characters (for example 000524). This number is incremented each time an entity sends a file. This sequence number does not depend on the file type, recipient or any other characteristic. It can start again at 000000 after 999999. If the same file is sent again, a new sequence number is provided. This number identifies uniquely a single file. Should a problem occur in the sending of a file, the sequence number will help identifying a unique file. [Timestamp] = YYYYMMDD 30/03/2012 Page | 11 Example of file name: BOV_TemplateA_SCV_000524_20120320.csv For each uploaded SCV file matching any of the templates mentioned in Section 3.2, the credit institution should also upload a corresponding header file. For the time-being, it is foreseen that this file will contain the total number of records uploaded in the corresponding SCV data file. Sequence number of the header file should precede that of the actual SCV file. In a similar way to the SCV file, the same naming conventions apply but HDR is used instead of SCV as shown below: [CreditInstitutionID]_ [TemplateID]_HDR_[SequenceNumber]_[Timestamp].csv Example of file name: BOV_TemplateA_HDR_000523_20120320.csv 3.4.1.2 Files further characteristics The data-entry encoding rules which constitute the records of files must be respected: • Alphanumeric fields: All type is allowed, either in capital or lower-case letter. (Exception: Hellenic Alphabet and Cyrillic script are not allowed). 3.4.1.3 Delivery modes The default mode in the DCS SCV system consists in an overwriting process for all data contained in the submitted file. This means that data coming from each credit institution will erase the data previously submitted if it has the same filename. Further than this, the information transmitted by any credit institution shall be retained in the SCV system until the liquidation proceedings are processed and all eligible compensations are duly paid out and the statutory prescription period will have elapsed. 3.4.1.4 Volumetric analysis A volumetric study will be carried out to identify the average maximum size of the files that will be exchanged with the DCS SCV system. This study should take into account the number of credit institutions that may potentially use this system in the eventuality that a credit institution fails. Depending on the final outcome of this study, SCV files may require to be compressed and encrypted using tools like WinZip before uploading them onto the DCS SCV hub. In this case to allow the DCS SCV team to process the file/s, you will also need to send the password in a separate email addressed to the DCS SCV system administrator. 3.4.2 Format and Structure of CSV Files The format of the CSV files should correspond to a flat file format: each data field is separated from one another by a “|”. One CSV file must only contain data common to: A single Excel Template from those specified in Section 3.2 3.4.2.1 Description of the Format Global organization of CSV file format is the following: Rows must be separated using a CR character (carriage return) Columns must be separated using pipe delimiter ( | ) 30/03/2012 Page | 12 Each single data must be surrounded by quote characters (“”) That includes empty values when allowed 3.4.2.2 Fields Description The templates attached here describe the data expected for each and every template. Template Template A Description Customer details File Template A.xlsx Template B Details of Account(s) Template B.xlsx Template C Claims against customer (With a right of set-off) Template C.xlsx Template D1 Aggregation details Template D1.xlsx Template D2 Compensation details Template D2.xlsx 3.5 Confidentiality In the event of any contractual arrangements entered into by the Scheme with a third party for the provision of any services on the processing and management of compensations, the third party shall be legally bound by a non-disclosure agreement. Furthermore, the third party will be bound to cleanse any data derived from the Scheme, on completion of its services to the Scheme. 3.6 Testing The Scheme’s electronic system and procedures are planned to be rigorously tested and will require the involvement of the member credit institutions in the process through the transmission of “dummy” or “real” data to the system. The use of “dummy” data processing is intended to enable the Scheme to receive data which does not factually reflect that of the existing customers of credit institutions (e.g. camouflaging depositors’ names, addresses and identification number details), thus ensuring that the customers’ confidentiality is maintained during any test processes. However, certain testing may be conducted on the basis of the actual descriptive and quantitative data held by the credit institutions (such as account balances, account status, individual aggregate balances of every customer) without the need to divulge the identity of any customer. Rigorous stress testing is also planned to be undertaken to the system to ensure that the SCV platform is a resilient one and is able to manage the maximum volume of data that may possibly be needed to be transmitted to the system. Other periodic tests will also be undertaken to ensure that 30/03/2012 Page | 13 all credit institutions are able to comply, on an on-going basis, with the transmission of the SCV information requirements to the Scheme. In addition to the testing exercises, the Scheme shall periodically request each credit institution to provide a certification from an external auditor, that it has its electronic SCV system in place and the credit institution is able to transmit electronically its SCV file containing live (real) data to the central SCV system, according to the Scheme’s regulations, at any time on request by the Scheme. 4 Revision of Schedule LD7 In order to achieve a more reliable assessment of the funding requirements of the Scheme, the Management Committee is currently reviewing the statutory return ‘Schedule LD7’, which every credit institution is obliged to provide periodically to the MFSA. The return contains the aggregated data on the amounts of eligible deposits held by every credit institution. The planned revision is intended to bring the schedule in line with the existing DCS regulations and to facilitate the calculation of the compensation funding required regarding the eligible deposits that are covered in terms of the statutory compensation limit of €100,000 per single customer. Amendments to the Explanatory Notes to Schedule LD7 are being proposed in order to enable credit institutions to report the required information as correctly as possible. A copy of the revised Schedule and Explanatory Notes is being included with this document marked as Annex 2. The Scheme is seeking feedback in this regard by not later than 15 May 2012. For ease of guidance, the main changes that are currently being proposed are as follows: Deletion of the ‘up to €22,000’ category to reflect the new compensation limit. Inclusion of two categories on ‘core information’ and ‘ancillary information’, which will encompass the aggregated data in euro area currencies and non-euro area currencies respectively and elimination of the USD and GBP sections. Introduction of ‘covered deposits’ which will include formulas calculating the aggregate compensation for the respective amount categories. Currently, credit institutions are required to submit Schedule LD7 on an annual basis. However, the Scheme intends to request such data to be provided on a more frequent basis, initially quarterly. 4.1 Annexes The documents related to the revised Schedule LD7 are annexed below: Annex Annex 1 Description File Schedule LD7 Schedule LD7 - Data on bank deposits.xls Annex 2 30/03/2012 Depositor Compensation Scheme – Explanatory Notes on Revised Schedule LD7 DCS - Explanatory Notes on Revised Schedule LD7.docx Page | 14