Response to consultation on draft ITS amending ITS on supervisory reporting on Liquidity Coverage Ratio
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The EBF supports the EBA’s proposal for 30 day remittance period and recommends it applies under normal circumstances (i.e. beyond the first months), and is shortened only when necessary (i.e. emerging or actual liquidity crisis).
The EBF supports EBA’s proposal.
Yes, the LCR calculation tool is indeed helpful, as it enables banks to understand how the correct calculation is to be undertaken.
Question 2: Do respondents agree with longer remittance dates for the first reference dates for the new templates for the first six months?
Please note our detailed comments in the attached document.The EBF supports the EBA’s proposal for 30 day remittance period and recommends it applies under normal circumstances (i.e. beyond the first months), and is shortened only when necessary (i.e. emerging or actual liquidity crisis).
Question 3: Do respondents agree with the implementation period suggested?
Please note our detailed comments in the attached document.The EBF supports EBA’s proposal.
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.
Please refer to our detailed comments in the attached document.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.
Please refer to our detailed comments in the attached document.Question 6: Do respondents consider that the “LCR calculation tool” appropriately translates the use of the different templates for informative purposes?
Please note our detailed comments in the attached document.Yes, the LCR calculation tool is indeed helpful, as it enables banks to understand how the correct calculation is to be undertaken.