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Banking and Payments Federation Ireland

We would request that the EBA consider the frequency of the requirement for the perimeter of consolidation.
As we note from other returns different templates can be accommodated on a different frequency (for example: FinRep template F.40 which is annual and COREP template C6 Group Solvency which is semi –annual, both of which include regulatory perimeter information).
Whilst annual may be too infrequent for LCR perhaps quarterly frequency could be accommodated. Whilst the main trading companies with cashflows tend to remain stable, in large organisations there can be more frequent changes as regards other entities, eg: wind up of dormant entities, which may have little or no liquidity impact but which will result in additional administrative overhead if a full listing is to be revalidated on a monthly basis and in time for the LCR submission date
Ali Ugur