The provisions in these RTS are clear but questionable. We understand the necessity of reporting sufficient data to the regulator and supervisor, in order to properly calibrate the leverage ratio during the monitoring period phase, but we are opposed to the disclosure of an excessive amount of data regarding the leverage ratio calculation.

As leverage ratio is not expected to be a binding measure and the BCBS has not yet decided whether it is going to be a pillar 1 measure or not, we think that the required data are overly demanding. For instance the “LRQua” template is seen as too intrusive (together with disclosing data related to encumbered assets or maturity mismatches). We don’t understand why the market should be aware of such granular information relative to leverage ratios of institutions.

From a general point of view we think it is unjustified to publicly disclose such a level of detailed information as for the monitoring period, especially at a time where there are still discussions in Basel regarding the definition of denominator of leverage ratio. We think that so detailed information highlight the leverage ratio to the detriment of the risk based ratio. Consequently, we would like the disclosures to be limited to LRSum template, completed with Tier 1 and ratio data. In all cases, it is important to re-use the data already provided for reporting purposes.

Moreover, any disclosures should be required at the consolidated level only, consistently with the approach which considers this ratio as a backstop and its calculation on a consolidated basis.

Again if a disclosure will be required, we believe it should not be aligned with reporting periods. Thus, the frequency of disclosure should not be more than yearly, and the location of publication would be at the discretion of the institution. We think it would be appropriate to provide the data into the registration document.