Response to consultation on draft ITS amending ITS on supervisory reporting on Liquidity Coverage Ratio

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Question 2: Do respondents agree with longer remittance dates for the first reference dates for the new templates for the first six months?

Yes, but see answer to Q1 above.

Question 3: Do respondents agree with the implementation period suggested?

Provided other concurrent LCR-related implementation burdens are kept to a minimum, it may be manageable, though still onerous for smaller institutions. There is a problem around the period October - December 2015.

Question 4: Do respondents agree to the structure and content of the proposed new LCR templates added for credit institutions? Particularly comments from respondents on specific rows, columns or any other item would be very valuable and appreciated including comments on the treatment of secured transactions.

N/A

Question 5: Do respondents find the new LCR instructions for credit institutions clear? Particularly comments from respondents on specific rows, columns or any other item would be very valuable and appreciated.

N/A

Question 6: Do respondents consider that the “LCR calculation tool” appropriately translates the use of the different templates for informative purposes?

N/A

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Name of organisation

Building Societies Association