1. Delegated Act on the Liquidity Coverage Ratio Brussels 10 March 2014 23/05/2015 Public Hearing

2. 23/05/2015

3. Definition of HQLA 1/2 1. Caps at 40% level 2A/15% level 2B 2. Should treatment for Covered Bonds be: a)As Level 2A assets (Basel and EBA Recs)? b)As Level 1 assets subject to RW (EBA analysis)? c)Other options: i. For some cov. bonds, increase L2A cap/lower haircut ii.Waive 75% inflow cap for interest income. 3. Should treatment for securitisations be: a)RMBSs as Level 2B assets? b)Other securitisations as non HQLA? 4. Committed liquidity facilities at central banks a)Should the delegated act include a (R) CLF and b)Should conditions regarding the pricing (and the asset quality) of the CLF be included, when such facilities fall under the exclusive prerogative of central banks? 3

4. 23/05/2015 5. Promotional bank bonds should be: a) HQLA depending on RW of guarantor (Basel)?; b) HQLA only if explicitly guaranteed by sovereign (EBA)?; 6. Mandatory cooperative deposits at the central institution: a)Basel: no HQLA+25%/100% outflow; 0% inflow for member bank b)CRR: HQLA +100% outflow; 0% inflow for member bank 7. What should be the operational requirements for HQLA? Comments are welcome on the EBA recommendations 4 Definition of HQLA 2/2

5. 1.Established operational relationships only Basel; Full EBA recommendations; intermediate? (e.g. Evidence, relationship at least 24 months, non-operational all balances in excess of the average 5 day rolling cumulative net-cash outflow over the preceding 90 days) 2. Natural person deposit threshold and retail deposit outflows a) Should LCR follow EBA guidelines / methodology / specify the higher outflows? b) In absence of EBA GL –set absolute ceiling for retail deposits by natural persons? c) Should interdependent outflows /inflows be considered? Under what conditions? 23/05/20155 Inflows / outflows

6. 3. Potential 3% retail deposit outflows? 4. Additional objective criteria for cross-border intragroup flows? (symmetric/asymmetric?) 5. Should outflow rates for committed liquidity/credit facilities: a) Apply a lower than 100% to non-financial corporates? b) Distinguish credit/liquidity facilities as in Basel?; c) Apply a lower than 100% to PICs and Trusts? 6. 75% Inflow cap exemption : I ntra-group/Institutional Protection Schemes specialised business models (pass-through financing models; promotional loans; auto/consumer loans, leasing and factoring, ) Covered bonds & UCITS bonds 23/05/20156 Inflows / outflows