Concerning the bonds with a qualifying guarantee by the European Central Bank, EU Member States' central government and central banks the relevance of the denominated and funded currency is unclear.

Provided that the guarantee is not dependent on the currency of the issued bonds, economically there is no difference between a bond issued in the domestic currency of the issuer or a foreign currency – the guarantor will be liable irrespective of the currency of the bond. Since the question of liability is the decisive factor to define government bonds, bonds with a qualifying guarantee provided by the European Central Bank, EU Member States' central government and central banks denominated in a foreign currency also qualify as government bond and consequently to CIC 1 third position. Please confirm our understanding. In case you do not follow our understanding, please explain the rationale.