EBA-ITS-2013-02 Article 18 (7) states: "for the period from 31 March 2014 to 31 December 2014 as a deviation from point (a) of Article 3 (1) the reporting remittance date relating to monthly reporting shall be the 30th calendar day after the reporting reference date". This would mean that the first submission of the LCR template should be by 30 April 2014, but we question whether this should also apply for the first submission of the SFR template? As things stand, it would appear that the first submission of the SFR template should be in line with Article 18 (6).
We think it makes sense that SFR first submission date should be aligned with LCR as opposed to being aligned with other quarterly COREP templates.
*As of 1/8/2014 the content of this answer was modified to reflect the publication of the final ITS on supervisory reporting of institutions in the Official Journal of the European Union. As a result, the references to the ITS were updated and the disclaimer deleted. For reasons of transparency, revisions are highlighted in track changes.
Article 18 of the Draft ITS on Supervisory reporting state that the first remittance date for information with a quarterly reporting frequency (which according to article 16 thereof, also includes the reporting on stable funding) shall be:- the 30 May at the latest for information to be reported on an individual basis; - and the 30 June at the latest for information to be reported on a consolidated basis. Information to be reported on a monthly basis, such as that on the liquidity coverage requirement, shall first be reported at the latest by the 30th calendar day after the 31 March 2014, i.e. by the 30 April 2014, according to article 18 of the ITS.