Response to consultation on amending ITS on additional monitoring metrics for liquidity

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Question 1: Do respondents agree to the structure and content of the maturity ladder template as proposed in Annexes XXIV and XXV, with in particular the items in the contingency section and memorandum item section? If not, would respondents have substantiated reasons for amending or not including a particular data item?

We would like to draw your attention to an inconsistent approach to retail deposits compared to their treatment in LCR.
In LCR the residual maturity of retail term deposit is based on the size of penalty for early withdrawal. If the penalty is sufficiently high, it is ignored and the residual maturity is determined on the basis of the originally agreed term of the deposit. If the penalty is low, the maturity is on the contrary determined on the basis of the nearest possible term of withdrawal. A Commission Regulation will determine what is the high penalty.
In AMM the approach to retail deposits is different. Regardless of the penalty size the residual maturity is always derived from the nearest possible term of withdrawal.
This inconsistent approach will unnecessarily require from banks to implement parallel systems for monitoring the residual maturity of retail term deposit, while it will not bring any significant benefit to supervisors. On the contrary, in our view this inconsistency will complicate the data processing. We believe that the principle for determining residual maturity of retail deposits in AMM should be consistent with LCR.

Question 2: Do respondents agree to the structure and content of the proposed revisions to the templates and instructions of the non-maturity ladder templates Annex XVIII to Annex XXI of Implementing Regulation 680/2014? If not, would respondents have substantiated reasons for not amending or further amending a particular paragraph or cell description?

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Question 3: Do respondents agree to the proposed clarification to the treatment of transactions that have rolled-over during the reporting period in paragraph 8 of the instructions to template C69.00 (as in annex XIX), or would it be preferable to have daily averaging of volumes and spreads as one alternative or end of month spreads as another (and why)?

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Question 4: Do respondents agree to the proposed clarification to the treatment of sight deposits in paragraph 9 of the instructions to template C69.00 (as in annex XIX), to focus only on those deposits that are new for the applicable reporting period, or would it be preferable to align the treatment with that of items that have rolled-over?

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Question 5: Would respondents have substantiated arguments for an implementation period different from the above-mentioned March 2018 application date?

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Question 6: Do respondents have substantiated views on the effectiveness and clarity of the proportionality threshold of subparagraph (a) of paragraph 16b (2) of the ITS on reporting? Would they see alternative workable solutions?

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Question 7: Do respondents agree to the impact assessment? If not, would respondents have substantiated reasons why they would foresee a different conclusion

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Name of organisation

Czech Banking Association