Market Link Guide - Bulgaria
CSD link as defined under CSDRa
Type of link
Indirect link to Central Depository AD (CDAD) via Eurobank Bulgaria AD
Direct Operated link to Bulgarian National Bank (BNB) via Eurobank Bulgaria AD
a. CSD Regulation (EU) No 909/2014, Article 2(29).
Central Depository AD (CDAD)
Bulgarian National Bank (BNB)
Eurobank Bulgaria AD
Country of incorporation
Mirror Omnibus account
Legal Account name / holder
CDAD: Clearstream Banking SA clients account
BNB: Clearstream Banking SA
Clearstream Banking SA clients account
|Settlement in T2S||No|
|Settlement free of payment||Yes|
|Settlement against payment||Yes|
|Settlement against payment in central bank money account of CBL/CBL customers||No|
CDAD: CBL holds a cash account at the Custodian. Against payment settlement in BGN takes place on the cash account of Eurobank Bulgaria at the Bulgarian National Bank.BNB: Not available.
|Settlement penalty fees||No|
|Pre-matching||Yes||Immediate release flag.|
|Registered securities||Yes||Registration takes place automatically upon settlement.|
|Multi Market Securities||No|
|Lending and borrowing||Yes|
|Investment Funds||Yes||CSD-eligible funds and ETFs.|
|Liquidity Hub Connect||No|
|Sale and purchase of rights||Yes|
|Link eligible for use in Eurosystem credit operations||No|
|Moment of entry of instructions|
BNB: 'The moment of entry of a transfer order (request) is considered to have entered in the ESROT system as soon as it has successfully passed the entry check and admitted to further processing.
CDAD: The moment of receiving syntactically matched messages.
|Irrevocability of instructions|
BNB: In case of matching requests from the two parties to the transaction, the transaction shall become irrevocable.
CDAD: The moment of participants’ messages matching and the formation of a common settlement request. After that moment no one can deny or cancel the transfer.
|Finality of instructions|
BNB: The settlement of government securities transactions shall be deemed final after crediting the government securities settlement account of the acquirer.
CDAD: The moment of transferring the money and the securities.
The below section is based on the legal opinion obtained by CBL that was issued on 26 March 2020 for the direct operated link and 12 February 2020 for the indirect link. The information is provided for guidance only and should not be considered in isolation or as constituting a complete or definitive legal advice on any specific matter.
No insolvency proceedings against the Account operator/Custodian
Liability for negligence
Book-entry regime with in rem rights
No entitlement of the Account operator/Custodian/CSD
Recognition as direct CSD account-holder
Recognition of nominee concept
Confirmed. While the nominee concept is not generally recognised under local law, CBL will be recognised as account holder of the accounts held in its name but on behalf of its underlying customers.
No right of retention to the Account operator/Custodian
Segregation of assets at the Custodian/CSD
No right of use
No upper-tier attachments
Although upper-tier attachments are not prohibited under local law, a third party affected by an upper tier attachment has the right to file a claim to ensure that its assets are not attached by a creditor.
Insolvency of the Account operator/Custodian/CSD with no impact on CBL's rights
Shortfall pro-rated among holders
Local law does not regulate specifically shortfall of securities, though a shortfall shall be borne by the account holders to whom the relevant securities have been allocated, while the Custodian/CSD shall be liable for any deficiencies.
|Record keeping period of at least 10 years||Confirmed|
Settlement finality in case of insolvency