The EACB welcomes the opportunity to comment on the draft EBA GLs on recovery plan indicators under Article 9 BRRD.
As a general comment regarding liquidity indicators, we would highlight that the current indicators are based on available figures which are subject to regulatory reporting. We believe that introducing new and unspecified indicators would not provide any added value. Instead, the existing well established metrics are familiar to supervisory authorities and institutions alike and should therefore continue to be used as recovery indicators. Well-established and consistently reported figures enable the supervisory authorities to continuously monitor the situation of the institution and allow meaningful comparisons across institutions.
Recovery indicators should generally directly build on available regulatory reporting to give reasonable workload to both supervisory authorities and institutions, therefore we see that the proposed indicator for the minimum list “c) Available unencumbered assets central bank’s eligible” should be adjusted in order to align it with the Asset Encumbrance Ratio already reported.