Reconciliation between Additional Liquidity? monitoring tools (ALMM) and FINREP

We have two questions pertaining to cross reporting controls. Pursuant to regulation re (UE) 2022/1994, C67 template (total of section 1 and section 2) shall be equal to the total of financial liabilities declared in FINREP. However, both reportings must be produced at different deadlines: - C67, as a monthly reporting, shall be submitted at the 15th calendar day after the reporting reference date - FINREP, as a quarterly report, shall be submitted 12 May, 11 August, 11 November, and 11 February The mismatch between these two dates makes it impossible in practice to comply with the new requirement and align the C67 with the FINREP on the same reference date. It also creates an unduly excessive administrative burden to systematically resubmit the C67 each quarter once the FINREP has been completed. Therefore, we would like to confirm with the EBA that the requirement means that institutions may use the figures of the FINREP of the previous quarter when performing the quarterly production of the ALMM (example: use of the Q3 FINREP data to report the Q4 ALMM) Does C68 statement also need to be reconciled with the FINREP? If yes, with which quarter end should be used as a reference, and which line should be used?

The regulation (UE) 2022/1994 states that, in additional liquidity monitoring tools, the total funding shall be all financial liabilities other that derivatives and short positions. For the template C67 (concentration of funding by counterparty), the regulation UE 2022/1994 also mention that the sum of Section 1 (Top ten Counterparties) and Section 2 (All other funding) “shall equal an institution’s total funding as per its balance sheet reported under the financial reporting framework (FINREP - representing financial liabilities adjusted for the exclusion of derivatives and short positions, in line with point2 from Section 1.1) for those reporting periods in which both reports are available (e.g. Finrep Q1 and C 67.00 March/Q1)”. It refers explicitly to the FINREP. We understand that regulation (UE) 2022/1994 was amended to make clear that the match should hold for those reporting periods in which both reports are available. But the FINREP is produced quarterly on fixed date roughly equivalent D+45 whereas the ALMM are produced on a monthly frequency at D+15. So, despite what is written in the regulation (“Finrep Q1 and C 67.00 March/Q1”), for quarterly closing, we cannot use the FINREP of the same quarter as it is produced 30 days after the C67 template.   The regulation (UE) 2022/1994 does not mention that the C68 template (concentration of funding by product type) must be reconciled with FINREP. However, it would make it clearer if the same rule applied as for the C67 report.