UK Finance is pleased to respond to the PRA’s CP22/18 consultation on Liquidity reporting: FSA047 and FSA048.
UK Finance has previously highlighted concerns around the introduction of PRA110, such as through our response to the consultation paper CP13/17 on Pillar 2 Liquidity. In this response we highlighted the significance of the additional reporting requirements of PRA110 and requested a longer implementation timeframe, which subsequently was moved from the original 1 January 2019 proposed start date, which we welcomed. We also expressed our concerns about the requirement to submit PRA110 on a T+1 basis which will apply significant pressure on firms in ensuring all data validation and control checks are complete, reviewed and signed off in a very short period of time. We suggested that a remittance period of two business days would serve to alleviate some of this pressure.