EBF response to EBA consultation on ITS on additional liquidity monitoring metrics under article 403(2) of the draft CRR

14 August 2013

Overall, EBF feels that the amount of new information to be reported to EBA is great and that the reporting templates are complex.

EBF welcomes the opportunity to comment on the EBA consultation paper related to the draft implementing technical standards on additional liquidity monitoring metrics under Article 403(2) of the draft Capital Requirements Regulation (CRR).

In general, EBF does agree with the scheme of reporting and the type of information required. However, with regard to the following:

• the reports must be produced both on an individual and consolidated basis;
• templates are numerous and particularly granular;
• in many cases, a reporting by currency is required;
• the proposed frequency is monthly;

EBF finds the impacts somewhat disproportionately severe and invasive. Overall, EBF feels that the amount of new information to be reported to EBA is great and that the reporting templates are complex. They will generate significant additional costs without necessarily creating much added value for banking supervision. EBF asks EBA to balance the added-value of the new reporting with their costs when setting the reporting framework, and to simplify the reporting framework. Moreover, EBF asks EBA to leave enough time to institutions to implement these new reporting templates.

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