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?


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

EBA's proposal to use either December 2015 or the point in time six months after publication of the implementing standard in the Official Journal presents the banks with the problem that, from 1 October 2015, the ratio of 60 per cent has to be complied with. However, calculation of the LCR on the basis of the delegated act by using the reporting sheets published with regulation (EU) No 680/2014 of 16 April 2014 is not possible. Therefore we plead for the early joint introduction of the new reporting forms at the effective date of the delegated act, i.e. 1 October 2015. This would ensure a consistent reporting of the LCR Data according to the rules of delegated act 2015/61, published 10 October 2014.

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.


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.

In our judgement, the instructions still lack information regarding the treatment of due, unsecured loans on securities. For example, it is not clear at the moment how and where these securities are to be entered once they are no longer capable of acting as a buffer but, nevertheless, have not yet been returned. The question of entry arises for both parties to the contract.
Also not clear is the question of the treatment of securities lending (maturity: until further notice). From a commercial point of view, such a transaction might be cancelled within 30 days at any time. From our point of view, the two parties to the contract may reflect this either as a cash inflow or a unilateral collateral swap or as a cash outflow or an outflow from the unilateral collateral swap.
Templates C73.00/C74.00 – Liquidity coverage outflows and inflows
According to the instructions, only cash-versus-collateral transactions are to be recorded in the cash outflow and inflow tables (see e.g. instructions regarding the cash outflows, no. 12). We interpret this to the effect that only repos / reverse repos are captured here.

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

We welcome the LCR calculation tool and consider it as helpful, as can help to understand how the correct calculation is to be undertaken.

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Name of organisation

German Banking Industry Committee