Response to consultation on RTS to specify the minimum contents of the liquidity management policy and procedures under MiCA
Question 1. Do respondents have any concerns of Article 1 for the identification, measurement and monitoring of liquidity risk of issuers? Do respondents think that the main aspects in the processes for issuers of tokens to properly manage liquidity risk are captured?
We recommend expanding paragraph 5 of Article 1 by indicating "Issuers of asset-referenced tokens and/or e-money institutions issuing e-money tokens that have to apply Article 45(3) of Regulation (EU) 2023/1114 shall have in place specific measures and limits to avoid concentration of the reserve of assets by custodian and adopt adequate policies that ensure a prudent diversification of custodians."
The aforementioned expanded statement will provide a clear summary of Section 3.2 of the Consultation on RTS, specifying the minimum contents of the liquidity management policy and procedures under MiCA, thereby reducing potential counterparty risks.
Question 2. Do respondents have any comment on the minimum content of the liquidity contingency policy proposed in Article 2? In particular, do respondents have any concern on the inclusion of the required indicator to measure deviations between the market value of the token and the market value of the assets referenced as an early warning signal to be calibrated by the issuer?
We do not have any comments.
Question 3. Do respondents find any challenge in the application of the segregation of the liquidity management policy as envisaged in Article 3?
Segregating liquidity management policies ensures that issuers can specifically address the unique risks associated with different types of tokens and facilitates transparency.
However, developing and maintaining distinct policies requires additional resources, including manpower, time, and financial investments. Issuers may find it particularly challenging to allocate these resources efficiently.
Question 4. Do respondents have any comment regarding the minimum content envisaged in Article 4 of these RTS about the liquidity stress testing under Article 45(4) of MiCAR to be included in the liquidity management policy?
The outlined requirements reflect a regulatory emphasis on transparency in liquidity risk management practices. This aligns with the broader approach in financial regulations to enhance risk management and disclosure standards.
We recommend highlighting, together with the historical data and assumptions, the external factors such as macroeconomic conditions, regulatory changes, and market trends in liquidity stress testing.
Additionally, we recommend establishing ongoing training programs for staff involved in liquidity risk management that will develop the liquidity risk management according to the current standards and practices.
Question 5. Do respondents find any provision unclear to apply?
We do not find any provision unclear to apply.
Question 6. Do respondents have any comment on the impact assessment provided?
We do not have any comment.