Response to consultation on Guidelines on the LCR disclosure
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Based on Para 7 of the GL, Art. 6(1) and (3) and Art. 13 CRR we understand that the LCR Disclosure GL will apply only for credit institutions that are not part of a group (on solo level) and for EU parent institutions (on consolidated level). Significant institutions of EU parent institutions will not be subject to the LCR Disclosure GL, as according to Art. 13/1 CRR they are subject to Part 8 of CRR (disclosure) only to a limited extent, with liquidity risk being excluded. This should be clarified in the LCR Disclosure GL. Art 7 of the GL in combination with the explanatory text for consultation purposes (which makes repeated reference to the broad scope and level of application of the Delegated Act LCR) leaves some uncertainties in this respect.
Question 1: Do respondents have any comment to the scope of application of the draft guidelines?
Supplement to our previous comments:Based on Para 7 of the GL, Art. 6(1) and (3) and Art. 13 CRR we understand that the LCR Disclosure GL will apply only for credit institutions that are not part of a group (on solo level) and for EU parent institutions (on consolidated level). Significant institutions of EU parent institutions will not be subject to the LCR Disclosure GL, as according to Art. 13/1 CRR they are subject to Part 8 of CRR (disclosure) only to a limited extent, with liquidity risk being excluded. This should be clarified in the LCR Disclosure GL. Art 7 of the GL in combination with the explanatory text for consultation purposes (which makes repeated reference to the broad scope and level of application of the Delegated Act LCR) leaves some uncertainties in this respect.