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Portuguese Banking Association (APB)

Although the APB fully agrees with the implementation of the additional monitoring metrics for liquidity reporting which helps competent authorities to identify potential liquidity difficulties, we have a major concern related with the template 70 - “Roll-Over of Funding”.

The submission of the Roll-Over of Funding report requires the analysis and treatment of an enormous and complex volume of transactions as it includes all financing operations that a bank carries out (each deposit, secured financing, wholesale funding operation, etc) on a daily basis and for its individual and consolidated perimeters (including other jurisdictions). The compliance costs associated with this specific template are, in our opinion, incommensurate with its benefits as other liquidity information is already being submitted to National/European supervisors, namely under the Short-Term-Exercise (STE), the remaining templates under the ALMM regulation as well as the information required by the SSM for the significant institutions within the “SSM Crisis Management Liquidity Reporting”.

Furthermore, we are doubtful as to the benefits this additional monthly report will bring to supervisors. Albeit being a report designed to evaluate daily positions over a 30-days period, it is reported on a monthly basis so the information received refers to daily positions going back 60 to 30 days from the reporting date. We find this situation at odds, especially when the SSM has explicitly excluded this template from all past reporting phases of the Short-Term-Exercise.

Finally, the principle of proportionality adopted by the Treaty of the European Union requires Community measures “do not exceed the limits of what is appropriate and necessary in order to attain the objectives legitimately pursued by the legislation in question”. Moreover, “when there is a choice between several appropriate measures, recourse must be had to the least onerous” and “the disadvantages caused must not be disproportionate to the aims pursued.”

In light of all the above, and considering that one of the main objectives of the new CRR and CRD IV revision is the reduction of the undesirable reporting burden trough a more comprehensive application of the proportionally principle, we urge the EBA to reassess the application of the principle of proportionality concerning the template 70 - “Roll-Over of Funding”.
In the aftermath of the financial crisis, the national competent authorities introduced national reporting requirements to monitor a set of liquidity metrics, which are much aligned with the content of the Implementing Regulation (EU) 2016/313. As of now, those national requirements are still in force in some EU countries simultaneously with the above mentioned regulation.

The duplication of liquidity reporting (national and European), with different definitions, formats and concepts, leads to an undesirable burden for banks, without any objective benefit neither for them nor for supervisors. The exclusion of the maturity ladder template from the Implementing Regulation has been presented by some NCAs as the major reason for not revoking such national ALMM reporting requirements.

As such, the APB fully supports a quick and timely implementation of the maturity ladder template in order to harmonize European practices through the implementation of a unique ALMM reporting framework across the EU and eliminate the current duplication observed in many countries.
Please see answear to Question 2 concerning the concept of proportionality principle.
Manuela Athayde Marques