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Investment Management Association

The information should be granular, include government and covered bonds, and distinguish between the types of securities and their currencies as risk profiles are different.
There should be information on asset quality. Some firms will have their own modus operandi, which may not mean anything to an external party, but, perhaps, reference to a specified pool of credit ratings agencies (CRAs), for example those CRAs that are part of the ECAI rules, should be considered.
Disclosure on the basis of median values and after six months is sufficient to avoid the detection of encumbrance at central banks and central bank support. Banks and securities firms should be weaned off such support, so this protection should not be permanent.
Yes, there should be disclosure as this will aid market discipline and risk management.
Such swaps should be disclosed, or be eventually disclosed, so that market participants are aware of the risk profiles of others.
The sources of encumbrance should be disclosed. A full picture is essential for risk mitigation.
Point in time is preferable in terms of accuracy, matching other disclosures, and (provides) the ability for counterparties and other assessors to build up their data, e.g. patterns.
We agree with the list in Template D.

The guidance should not, or not for long, exempt ELA. Please see our covering letter in this regard.
Six months is sufficient lag to avoid a negative impact.
Irving Henry
00 44 (0) 20 7831 0898