Submission #17

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EACB - European Association of Co-operative Banks

Question 1: Do respondents have any comment to the scope of application of the draft guidelines? Please see attached document.

Question 2: As currently foreseen, the application date will be in June 2017. Do respondents find the date of application of the guidelines appropriate? Please see attached document.

Question 3: Do respondents consider that the transitional period is sufficiently clear? Please see attached document.

Question 4: Do respondents have any comment relative to the proposed LCR related items prone to rapid change? Please see attached document.

Question 5: Do respondents have any comment relative to the content of the table in Annex I of the draft guidelines and the way to display it? Please see attached document.

Question 6: Do respondents have any comment on the content of the LCR disclosure template in Annex II? Please see attached document.

Question 7: Do respondents have any comment relative to the content of the template on qualitative information on LCR? Please see attached document.

Question 8: What information from Annex II, if any, would respondents consider irrelevant for LCR disclosure purposes? Please see attached document.

Question 9: What information would respondents like to see added to the LCR disclosure requirements? Please see attached document.

Question 10: Do respondents find the general instructions in Annex III sufficiently clear for the development of the disclosure template? Please see attached document.

Question 11: Do respondents consider that the methodology proposed for the LCR disclosure template is, from a practical point of view, operationally feasible meaning that the accuracy of the daily reporting observations for the calculation of the averages can be ensured? Do respondents consider that this operational feasibility could depend on the size of the credit institution or could be different in the case of solo or consolidated data? Please see attached document.

Question 12: Do respondents find the specific instructions in Annex III sufficiently clear for the development of the LCR disclosure template and the template on qualitative information on LCR in Annex II? Please see attached document.

Question 13: In the elaboration of this CP, the EBA has considered several policy options under three main areas: a proportionality approach in the scope of application, items for a higher disclosure frequency and methodology for the calculation of the disclosures. Do respondents have any particular view on the assessment conducted on these policy options? Please see attached document.

Question 14: Do respondents think that the opportunity of having a simplified disclosure template for smaller credit institutions should be assessed? This simplified LCR disclosure template could comprise for example the ratio itself, the numerator and the denominator as key ratios and figures of the LCR, in the sense of Article 435 (1) (f) CRR. What arguments could respondents provide to justify that the LCR ratio itself, its numerator and its denominator are the only key ratios and figures of the LCR which are required to be disclosed by smaller credit institutions? More generally please provide any argument in favor or against a simplified template, and if you believe a simplified template for LCR disclosures is relevant, please indicate which type of information you would like to have disclosed in that template. What specific criteria would respondents suggest to identify those smaller institutions for which a simplified disclosure template could potentially be disclosed? Please see attached document.

Upload files EACB Comments on draft EBA GL LCR disclosure_20160811.pdf

Name of organisation EACB - European Association of Co-operative Banks