Submission #8

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European Banking Federation

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?

Please note our detailed comments in the attached document.
The EBF supports EBA’s proposal.

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

Please note our detailed comments in the attached document.

The EBF supports the EBA’s proposal for 30 day remittance period and recommends it applies under normal circumstances (i.e. beyond the first months), and is shortened only when necessary (i.e. emerging or actual liquidity crisis).

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

Please note our detailed comments in the attached document.

The EBF supports EBA’s proposal.

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. Please refer to our detailed comments in the attached document.

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. Please refer to our detailed comments in the attached document.

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

Please note our detailed comments in the attached document.

Yes, the LCR calculation tool is indeed helpful, as it enables banks to understand how the correct calculation is to be undertaken.

Upload files EBF_012571 - EBF Response EBA-CP-2014-45 supervisory reporting LCR v5 final.pdf

Name of organisation European Banking Federation