Market Link Guide - Bulgaria

07.02.2022

Key features

CSD link as defined under CSDRa

Yes

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).

CSD

Custodian/Account operator

Name

Central Depository AD (CDAD)

Bulgarian National Bank (BNB)

Eurobank Bulgaria AD

FATCA GIIN

Not available

0T0F5N.00005.ME.101

LEI

CDAD: 74780000G07H7WL0WI31

BNB: 5299001WEKCK7E65TI48

549300IRGNL8Q3O8Y413

Country of incorporation

Bulgaria

Bulgaria

Account type

Omnibus account

Omnibus account

Mirror Omnibus account

Legal Account name / holder

CDAD: Clearstream Banking SA clients account

BNB: Clearstream Banking SA

Clearstream Banking SA clients account

Operational arrangements

Yes/NoRemarks
Settlement in T2S

No

Settlement free of paymentYes  
Settlement against paymentYes 
  •  Against payment settlement only for securities that settle in CDAD;
  •  Eligible settlement currency: Bulgarian Lev (BGN).
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.
Bridge settlement

No

 
Shaping facility

No

 

Hold and Release

No

Please see details in Settlement services

Partial settlement

No

 

Recycling

Yes

Please see details in Settlement services

Bilateral cancelation

Yes

Please see details in Settlement services

Settlement penalty fees

Yes

Please see details in Settlement services

Pre-matching

Yes

Immediate release flag.

Back-to-back processing

No

 
Allegements

Yes

 
Automatic compensation

No

 
Registered securities

Yes

Registration takes place automatically upon settlement.

Multi Market Securities

No

 
Lending and borrowing

Yes

 
Proxy voting

Yes

 
Investment Funds

Yes

CSD-eligible funds and ETFs.

Liquidity Hub Connect

No

 
Sale and purchase of rights

Yes

 
Repo services

Yes

 
Market restrictions

No

 
FTT

No

 
Daily reconciliation

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.

Legal arrangements

The below section is based on the legal opinion obtained by CBL that was issued on 22 October 2021 for both the direct operated link and 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

Confirmed

Liability for negligence

Confirmed

Book-entry regime with in rem rights

Confirmed

No entitlement of the Account operator/Custodian/CSD

Confirmed

Recognition as direct CSD account-holder

Confirmed

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

Confirmed

Segregation of assets at the Custodian/CSD

Confirmed

No right of use

Confirmed

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 

Confirmed

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

Confirmed