The members of the EACB welcome the opportunity to comment on the Commission draft text for the amendment of the Delegated Regulation (EU) 2015/61 of 10 October 2014, i.e. the LCR delegated act.
We truly appreciate that this exercise is done in a transparent manner and that the industry has the opportunity to submit feedback via a fully-fledged consultation.
Overall we see that most of the adjustments are of a targeted nature and aim to address a number of elements that needed alignment with the international standards. However, some of the proposed amendments do not reflect such spirit and introduce questionable novelties while others require clarifications.
In addition we would also call for amending the EBA LCR template only once the new delegated act is in force, and no longer than six months after, to avoid overlaps that may lead to uncertainty and undue reporting burden.