European Savings and Retail Banking Group

The solution put forward seems to be unnecessarily complicated in particular when it comes to the requests to predict the need for other assets and to notify authorities 30 days in advance. This may turn out to be almost impossible.
No comments on this particular point. See the ESBG common response.
In our view, the RTS additional conditions set up for those banks that want to use either of the 2 derogations are acceptable. Moreover, we fully support the EBA’s view that the use of derogations should be minimised. However, in the Norwegian case, excluding the largest asset class which is covered bonds will significantly increase the need for these derogations. The use of foreign currencies to fulfil the LCR-requirements will increase the currency risk in the Norwegian banking sector. This will especially be problematic for smaller banks, as they do not have foreign exposures as a significant or natural part of their businesses. For these banks the second alternative of credit lines from the central bank will be the only derogation available. Typically, banks will be resistant to use the liquidity available through such facilities due to the following negative market assessment. The lines will then represent more a cost than actual liquidity.
No comments on this particular point. See the ESBG common response.
it is somewhat unclear how the 8% haircut has been obtained, and also if this figure is actually accurate.
In our view, the RTS additional conditions set up for those banks that want to use either of the 2 derogations are acceptable. Moreover, we fully support the EBA’s view that the use of derogations should be minimised. However, in the Norwegian case, excluding the largest asset class which is covered bonds will significantly increase the need for these derogations. The use of foreign currencies to fulfil the LCR-requirements will increase the currency risk in the Norwegian banking sector. This will especially be problematic for smaller banks, as they do not have foreign exposures as a significant or natural part of their businesses. For these banks the second alternative of credit lines from the central bank will be the only derogation available. Typically, banks will be resistant to use the liquidity available through such facilities due to the following negative market assessment. The lines will then represent more a cost than actual liquidity.
In our view, the RTS additional conditions set up for those banks that want to use either of the 2 derogations are acceptable. Moreover, we fully support the EBA’s view that the use of derogations should be minimised
No comments on this particular point. See the ESBG common response.
No comments on this particular point. See the ESBG common response.
César Blanco Martínez
E