We support efforts to introduce global standards of liquidity for deposit takers and appreciate the need of regulators for accurate, comparable, relevant and timely information to enable them to supervise and monitor risks.
Like our members, we are keen to engage with the European Banking Authority to ensure that the business of mutually-owned deposit takers, in particular their low risk business models and mutual ownership structures, are properly understood.
As the EBA has itself acknowledged, one problem with tying the liquidity reporting framework with COREP is that COREP has not yet been finalised or agreed (though in the UK, the national authority, the FSA, has confirmed it will implement it from 1 July 2013). An associated problem is that the EBA has developed the reporting requirements on an early draft of CRR/ CRD 4, which has since been amended in the trialogue process. As well as the risk of lack of clarity on guidance and definitions, this may well lead to institutions using temporary templates which have to be changed at a later stage.
Click below to read the full response:
Our response to EBA on reporting of LCR and stable funding ratio