The members of the EACB welcome the opportunity to comment on the EBA draft Guidelines (GL) on LCR disclosure to complement the disclosure of liquidity risk management under Article 435 CRR.
While we appreciate this transparency effort, we believe that it has to be ensured that such an own initiative to impose Pillar 3 disclosure requirements does not exceed the mandate of level 1 legislation by introducing even more far-reaching requirements.
We also believe that the requirement to disclose LCR based on an average of daily LCR calculations is excessive and would present major issues of data quality and operational feasibility.
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