UK Finance response to the PRA's CP19/21 on changes to the Domestic Liquidity Sub-Groups

In its response to the PRA's consultation CP19/21 UK Finance was supportive of changes proposed to the  Domestic Liquidity Sub-Groups (DoLSubs) regime.

These permit the application of the Liquidity Coverage Ratio and Net Stable Funding Ratio prudential liquidity requirements on a sub-consolidated basis, rather than at the level of individual firms that are part of a banking group. Firms must submit a waiver application to the PRA requesting that they be allowed to adopt the DoLSub approach, which  allows the optimisation of sources of liquidity, avoiding expensive trapped pools of liquidity.

But we noted that banks are already in the process of applying for DoLSub approval under the current rules. We suggested that a pragmatic approach that would allow banks to 'top-up? current waiver requests by providing supplemental information required under the proposed new rules would be welcome. This would be optimise both banks and the PRA resources enabling the waiver application to be completed in time for the I January 2022 implementation date.  

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Consultation Responses