13 August 2012

EBF Response to EBA consultation Paper Draft ITS on supervisory reporting requirements for liquidity coverage and stable funding

Timing of Implementation

The EBF proposes 1 January 2014 as an appropriate implementation date in respect of the liquidity reporting requirements, as the final technical standards are not likely to be available before January 2013. It is unreasonable to expect banks to design, develop and test systems solutions before the final technical standards and the final legal text of CRR/CRD IV are available. Reporting up to 1 January 2014 could be run quarterly using the 2012 EBA Voluntary QIS template and having 2012 end of year as the first reference date.

Remittance Dates:

Remittance at D+15 is not feasible, and is not desirable as it would be detrimental to the data quality. EBF and its members would also recommend a phased liquidity reporting approach of allowing more time at the beginning, such as 60 days, then falling to 45 days and finally 25 working days. Otherwise, if data is provided before institutions are able to finalise their systems and controls, the data may not be of the desired quality.

Proportionality:

Whilst CRR/CRD IV does not allow the EBA to apply the principle of proportionality to the application of the reports, this will potentially lead to very small legal entities having to complete the new reports. EBF does not believe this to be in the interest of either the EBA or the banks, and would ask the EBA and the Commission to take this problem up in the Trialogue. EBF strongly urges that QIS reporting up to 1 January 2014 will not be extended to small banks (not used to running the QIS templates) or at least be limited to only a small sample of small and medium-sized banks on a voluntary basis.

Reference with COREP:

EBF Members are surprised that the EBA draft ITS on liquidity reporting include a reference to COREP taking into account (i) that COREP refers to the asset-side of the balance sheet only and, moreover, (ii) that it only concerns risk data. The EBF therefore questions the reference made to COREP. The 18 July EBA Hearing suggested that the reference was more on the XBRL format used in the COREP report. The EBF would welcome clarifications on this reference.

Full response

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