Question
What is the (combined) treatment of liquid assets held by and liquidity inflows arising in third country subsidiaries being subject to transfer restrictions for the purpose of the calculation of the LCR at consolidated level?
Background on the question
For the purpose of the calculation of the LCR at consolidated level, Articles 8(2) LCR DR and 32(8) LCR DR combined appear to define the framework for the recognition of liquid assets held by and liquidity inflows arising in third country entities in the case of transfer restrictions. As such, the EU framework appears different to Basel LCR10.7 according to which liquid assets held by a legal entity being consolidated can be included in the consolidated LCR to the extent that such liquid assets are used to cover the total net cash outflows of that entity, notwithstanding that the assets are subject to liquidity transfer restrictions. Consider, for instance, a subsidiary in a third country which is being considered "trapped" and which reports, at individual level, liquid assets of 300 units, liquidity outflows of 180 units, and liquidity inflows (before cap) of 100 units.
Answer
This question has been rejected because the issue it deals with is already explained or addressed in Article 8(2) and Article 32(8) of the LCR DR.