Submission #3

Deutsche Bank

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? No specific comments.

Question 2: Do respondents agree with longer remittance dates for the first reference dates for the new templates for the first six months?

A 30 day remittance period for the six months post implementation would provide additional time for verifying the data to be submitted.

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

Due to time and operational restraints for both the EBA and firms, it would not be feasible to implement the revised templates before December 2015. Therefore, additional guidance is necessary on how compliance to the LCR will be monitored between 1 October 2015 and the proposed first reference date. Should competent authorities require additional reporting during this period we would appreciate that notice be given as soon as possible and that a consistent approach is taken across member states.

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.

We appreciate the work the EBA has undertaken to improve the structure and content of the LCR templates. Additional suggestions for further clarifications on specific reporting lines are included in Appendix 1 of our response.

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.

Comments on the reporting instructions are included in Appendix 2 of our response

Question 6: Do respondents consider that the “LCR calculation tool” appropriately translates the use of the different templates for informative purposes? No specific comments.

Upload files DB response to EBA consultation on supervisory reporting on LCR.pdf

Name of organisation Deutsche Bank