FRENCH BANKING FEDERATION

Yes, we agree.
• The decision to rely on local jurisdictions to evaluate the currencies outside EEA makes sense. However it should be noted that it introduces uncertainties for European banks since CRR-LCR will be binding before those analyses are completed;
• The currencies for which the justified demand for liquid assets exceeds the availability of those assets: we regret that the analysis has not been conducted on other currencies because data to complete the analysis could not be obtained by the EBA. Notably we are particularly concerned by the absence of analysis on the EUR currency.
Yes, we agree.
• The decision to rely on local jurisdictions to evaluate the currencies outside EEA makes sense. However it should be noted that it introduces uncertainties for European banks since CRR-LCR will be binding before those analyses are completed;
• The currencies for which the justified demand for liquid assets exceeds the availability of those assets: we regret that the analysis has not been conducted on other currencies because data to complete the analysis could not be obtained by the EBA. Notably we are particularly concerned by the absence of analysis on the EUR currency.
Yes, we agree.
• The decision to rely on local jurisdictions to evaluate the currencies outside EEA makes sense. However it should be noted that it introduces uncertainties for European banks since CRR-LCR will be binding before those analyses are completed;
• The currencies for which the justified demand for liquid assets exceeds the availability of those assets: we regret that the analysis has not been conducted on other currencies because data to complete the analysis could not be obtained by the EBA. Notably we are particularly concerned by the absence of analysis on the EUR currency.
Yes, we agree.
• The decision to rely on local jurisdictions to evaluate the currencies outside EEA makes sense. However it should be noted that it introduces uncertainties for European banks since CRR-LCR will be binding before those analyses are completed;
• The currencies for which the justified demand for liquid assets exceeds the availability of those assets: we regret that the analysis has not been conducted on other currencies because data to complete the analysis could not be obtained by the EBA. Notably we are particularly concerned by the absence of analysis on the EUR currency.
We do not agree with point 9 in the draft cost-benefit analysis.
David Labella
F