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Response to consultation on amended ITS on currencies with constraints on the availability of liquid assets
Go backQ1: Are the proposed amendments appropriate and sufficiently clear?
The EAPB would like to comment on the EBA’s underlying analysis with regards to availability of level 1 assets issued by international institutions and multinational development banks. In the Regulation 2015/2344 in force, it is stated in recital 7 that these types of issues are predominantly private placements held by overseas investors and were therefore not considered by the EBA as liquid and available for institutions. In the consultation paper page 7 there is an overview of (gross) supply of liquid assets. It seems from this overview (and from the first table at page 8) that level 1 assets issued by international institutions and multinational development banks are now fully included in the supply of level 1 assets. The EAPB would encourage the EBA to ensure that the evidence from the markets supports a change of stance on this issue and, if supported by the evidence, explain the basis for the change of view on the availability for institutions for these types of issues. If increased availability cannot be supported, removing NOK from the regulation may not be merited. The EAPB in any case finds it important that the underlying analysis for updating the regulation is accurate. Name of the organization
The European Association of Public Banks (EAPB)
