Response to consultation on draft ITS amending ITS on supervisory reporting on Liquidity Coverage Ratio

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Question 2: Do respondents agree with longer remittance dates for the first reference dates for the new templates for the first six months?

The possibility to submit the liquidity reports during a transition phase for the first reference dates with a remittance period of 30 instead of 15 days shall indeed be useful for the reporting entities in order to promote a better reporting quality during the first submissions.

Question 3: Do respondents agree with the implementation period suggested?

From our point of view, the envisaged six months transition phase for the application of the before mentioned longer remittance dated might not be sufficient to allow all reporting entities a successful implementation of the new reporting and liquidity management requirements. Although there is an already existing experience in reporting LCR under the current provisions, the aforementioned facts about the various difficulties concerning the liquidity regulations (cf. question 1), we propose a transition phase of 12 months.

Question 4: Do respondents agree to the structure and content of the proposed new LCR templates added for credit institutions? Particularly comments from respondents on specific rows, columns or any other item would be very valuable and appreciated including comments on the treatment of secured transactions.

It might be helpful for the implementation of the new liquidity reporting requirements that the templates of the new Annex XXIV keep the overall structure of the so far applicable Annex XII.

Bearing in mind the already mentioned difficulties accompanying the implementation of the new liquidity reporting requirements (cf. question 1), any implementation measures carried out by the credit institutions will be further burdened if the reporting templates are expanded with items that shall be reported although they may not be directly necessary for the LCR calculation (so-called “Memorandum”). The Memorandum involves the following rows in the LCR-templates:
• rows 480 - 610 in template C 72.00 – Liquidity Coverage – Liquid Assets
• rows 1140 - 1390 in template C 73.00 – Liquidity Coverage – Outflows
• rows 440 - 520 in template C 74.00 – Liquidity Coverage – Inflows
• rows 740 - 760 in template C 74.00 – Liquidity Coverage – Collateral Swaps

We understand that there might be a necessity for the supervisors to gain this additional information and that the Memorandum items might therefore be considered as appropriate for supervisory purposes. Otherwise, it is from our point of view quite ambitious to add further reporting requirements before the background of the nonetheless difficult challenge to implement the revised reporting following the Commission Delegated Regulation (EU) 2015/61.

We therefore propose to introduce the Memorandum as a mandatory reporting requirement to the Commission Implementing Regulation (EU) No 680/2014 after the end of the transition period of twelve months, as set out in our comment to question 3.

Question 5: Do respondents find the new LCR instructions for credit institutions clear? Particularly comments from respondents on specific rows, columns or any other item would be very valuable and appreciated.


Question 6: Do respondents consider that the “LCR calculation tool” appropriately translates the use of the different templates for informative purposes?


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Name of organisation

Association of Foreign Banks in Germany