The EACB welcomes the opportunity to comment on the draft EBA ITS amending the supervisory reporting requirements with regard to Additional Liquidity Monitoring Metrics (ALMM).
We appreciate the EBA’s efforts to take a more proportionate approach from a practical perspective. We believe it would be essential to allow institutions to benefit from the adjusted requirements as soon as possible, ideally before the end of 2022.
We have to note, however, that contrary to the spirit of this consultation the reporting cycle on ALMM for banks with total assets between € 5bn and 30bn has recently become more burdensome. We believe that for those institutions, the quarterly reporting cycle as previously envisaged should be reintroduced.
With regard to the removal of the 1% threshold in C 67.00 and C 68.00 we do welcome the approach in principle. However, the removal in C 67.00 would lead to higher manual effort and hence to higher costs which would outweigh the benefits, in particular with regard to data collection. Maintaining the 1% threshold in C 67.00 is also in line with the EBA findings in the Cost of Compliance study where it is indicated that while two thirds of respondents considered the 1% threshold ineffective in context of template C 68.00, this was not the case for C 67.00.
We believe that also the frequency of reporting for C 71.00 should be revised. An annual reporting cycle would be sufficient at least for SNCIs, as the top ten issuers that granted assets or liquidity lines to the reporting institution, that are part of its counterbalancing capacity, rarely change. For other institutions a quarterly frequency also seems more adequate than the monthly one.
Moreover, we believe that some of the changes proposed do not reveal a clear technical/supervisory benefit. Considering that the stated aim is reducing the reporting burden, changes should have a clear added value. In the C 66.01, institutional protection scheme (IPS) flows were moved to the main inflows/outflows part of the template instead of memo items. We do not see any enhanced informative value in this, which rather only causes unnecessary implementation costs. The desired improvement in data quality could instead be achieved by more rigorously demanding the memo items.