Market Link Guide – Bulgaria
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 | WSN3WC.00006.ME.100 |
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 S.A. clients account BNB: Clearstream Banking S.A. | Clearstream Banking SA clients account |
Operational arrangements1
| Yes/No | Remarks | |
| Settlement in T2S | Yes | Only for EUR-denominated securities |
| Settlement free of payment | Yes | |
| Settlement against payment | Yes |
|
| Settlement against payment in central bank money account of CBL/CBL clients | No | CDAD/BNB: CBL holds a cash account at the custodian. Against payment settlement in BGN and in EUR takes place on the cash account of Eurobank Bulgaria at the Bulgarian National Bank and in TARGET2-Securities (T2S). |
| 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. T2S: The moment of successful validation in T2S. |
| Irrevocability of instructions | BNB: If there are 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. T2S: The moment when the instruction receives "matched" status in T2S. |
| 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. T2S: The moment when the instruction receives "settled" status in T2S. |
Legal arrangements
The below section is based on the legal opinions obtained by CBL that were issued on 14 December 2023 (BNB – direct operated link) and 5 December 2023 (CDAD – 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 client. |
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 |