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Association of Danish Mortgage Banks

We are concerned about the level of disclosure of qualitative information. The information requirements under Annex 1 are very detailed and nearly corresponds with the require-ments under the ILAAP. The value of providing the information to stakeholders will not be proportional with the negative effect of providing sensitive information to competing credit institutions.
The requirement to disclose an average LCR based on daily observations lacks in our opinion consistency with the requirements on monthly frequency of LCR reporting according to the Commission Implementing Regulation.
We are also concerned with the requirement to disclose LCR based on an average of daily LCR calculations as the disclosed figures will not be comparable with the LCR figures reported to the supervisor. Furthermore it will be burdensome and costly for the mortgage banks to implement a disclosure on daily observations and the information do not give added value to the market participants.
Mette Saaby Pedersen