Response to consultation on Guidelines on the LCR disclosure

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Question 5: Do respondents have any comment relative to the content of the table in Annex I of the draft guidelines and the way to display it?

We are concerned about the level of disclosure of qualitative information. The information requirements under Annex 1 are very detailed and nearly corresponds with the require-ments under the ILAAP. The value of providing the information to stakeholders will not be proportional with the negative effect of providing sensitive information to competing credit institutions.

Question 11: Do respondents consider that the methodology proposed for the LCR disclosure template is, from a practical point of view, operationally feasible meaning that the accuracy of the daily reporting observations for the calculation of the averages can be ensured? Do respondents consider that this operational feasibility could depend on the size of the credit institution or could be different in the case of solo or consolidated data?

The requirement to disclose an average LCR based on daily observations lacks in our opinion consistency with the requirements on monthly frequency of LCR reporting according to the Commission Implementing Regulation.
We are also concerned with the requirement to disclose LCR based on an average of daily LCR calculations as the disclosed figures will not be comparable with the LCR figures reported to the supervisor. Furthermore it will be burdensome and costly for the mortgage banks to implement a disclosure on daily observations and the information do not give added value to the market participants.

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Name of organisation

Association of Danish Mortgage Banks