Response to consultation on RTS to specify the minimum contents of the liquidity management policy and procedures under MiCA
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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?
The EBA’s proposal for mandatory over-collateralisation of reserve assets is unnecessary and should be removed. For the same reasons set out in our response to Q7 in relation to the draft RTS “to further specify the liquidity requirements of the reserve of assets under Article 36(4) of MiCA” which is also currently being consulted on, the objective of ensuring that the market value of reserve assets cover the market value of the ART/significant EMT for the purposes of meeting redemption requests is already met through other MiCA requirements.