With the beginning of the application of the Commission Delegated Regulation (EU) 2015/61 of 10 October 2014 concerning the LCR on 1 October 2015, a great number of changes with regards to the liquidity management and reporting process has to be implemented by the supervised entities. Bearing in mind the relatively late publication of the Commission Delegated Regulation in the EU Official Journal, the credit institutions face a challenge to adapt their liquidity management and reporting process to the new requirements until 1 October 2015. Furthermore, the still pending adoption of the ITS on additional liquidity monitoring metrics by the European Commission impede the credit institutions’ efforts to plan their future compliance to the designated liquidity requirements.
In general, we acknowledge EBA’s plan to introduce longer remittance dates for the first reference dates during the first months. Bearing in mind the aforementioned facts about the difficult implementation measures to be taken by the credit institutions, a limitation of this period to six months might not be sufficient. We therefore propose a longer implementation period (cf. question 3).
The possibility to submit the liquidity reports during a transition phase for the first reference dates with a remittance period of 30 instead of 15 days shall indeed be useful for the reporting entities in order to promote a better reporting quality during the first submissions.
From our point of view, the envisaged six months transition phase for the application of the before mentioned longer remittance dated might not be sufficient to allow all reporting entities a successful implementation of the new reporting and liquidity management requirements. Although there is an already existing experience in reporting LCR under the current provisions, the aforementioned facts about the various difficulties concerning the liquidity regulations (cf. question 1), we propose a transition phase of 12 months.
It might be helpful for the implementation of the new liquidity reporting requirements that the templates of the new Annex XXIV keep the overall structure of the so far applicable Annex XII.
Bearing in mind the already mentioned difficulties accompanying the implementation of the new liquidity reporting requirements (cf. question 1), any implementation measures carried out by the credit institutions will be further burdened if the reporting templates are expanded with items that shall be reported although they may not be directly necessary for the LCR calculation (so-called “Memorandum”). The Memorandum involves the following rows in the LCR-templates:
• rows 480 - 610 in template C 72.00 – Liquidity Coverage – Liquid Assets
• rows 1140 - 1390 in template C 73.00 – Liquidity Coverage – Outflows
• rows 440 - 520 in template C 74.00 – Liquidity Coverage – Inflows
• rows 740 - 760 in template C 74.00 – Liquidity Coverage – Collateral Swaps
We understand that there might be a necessity for the supervisors to gain this additional information and that the Memorandum items might therefore be considered as appropriate for supervisory purposes. Otherwise, it is from our point of view quite ambitious to add further reporting requirements before the background of the nonetheless difficult challenge to implement the revised reporting following the Commission Delegated Regulation (EU) 2015/61.
We therefore propose to introduce the Memorandum as a mandatory reporting requirement to the Commission Implementing Regulation (EU) No 680/2014 after the end of the transition period of twelve months, as set out in our comment to question 3.
