Submission #2

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Building Societies Association

Question 1: The EBA deems it appropriate to keep the remittance dates unchanged in a steady state regime. While the content of the templates is changed, the objective of the supervisory reporting keeps unchanged and the present ITS constitutes only an update of the current existing reporting requirements for the LCR. This means that, once the current ITS is adopted, and after a transition phase, credit institutions would have to remit the monthly reports on each following 15th calendar day as this will be the case starting 1 January 2015 under the existing ITS on reporting for the LCR. Nevertheless, the EBA deems it appropriate to introduce longer remittance dates for the first reference dates during the first months, to be limited to a period of six months. Do respondents have arguments to put forward a change on these aspects?

In line with our general comments about the cumulative burdens, the longer remittance dates should on this occasion continue for say twelve months.

Question 2: Do respondents agree with longer remittance dates for the first reference dates for the new templates for the first six months? Yes, but see answer to Q1 above.

Question 3: Do respondents agree with the implementation period suggested?

Provided other concurrent LCR-related implementation burdens are kept to a minimum, it may be manageable, though still onerous for smaller institutions. There is a problem around the period October - December 2015.

Question 4: Do respondents agree to the structure and content of the proposed new LCR templates added for credit institutions? Particularly comments from respondents on specific rows, columns or any other item would be very valuable and appreciated including comments on the treatment of secured transactions. N/A

Question 5: Do respondents find the new LCR instructions for credit institutions clear? Particularly comments from respondents on specific rows, columns or any other item would be very valuable and appreciated. N/A

Question 6: Do respondents consider that the “LCR calculation tool” appropriately translates the use of the different templates for informative purposes? N/A

Upload files BSA response EBA CP 2014 45.pdf

Name of organisation Building Societies Association