OSFI's response to the Liquidity Adequacy Requirements Guideline (2025) consultation feedback

Summary of stakeholder comments and our responses

Scope of application
Stakeholder feedback Our response
Stakeholders recommended limiting the scope of intraday liquidity monitoring to direct clearers. At a minimum, stakeholders requested implementation timelines be extended in order for non-direct clearers to develop the tools and systems required to implement these new reporting requirements. We have modified the scope of the regulatory reporting requirements such that only direct clearers in Lynx will be required to submit the intraday liquidity regulatory return. However, given the relevance of intraday liquidity risk, many of the monitoring tools in the guideline will continue to be applicable to all institutions, both direct and non-direct clearers of the payments system.
Intraday liquidity sources and use
Stakeholder feedback Our response
Stakeholders noted that the term “reserves at the Bank of Canada” has multiple interpretations and requires clarity. We have changed “reserves at the Bank of Canada” to “deposits with central bank” for clarity and consistency with other liquidity returns.
Stakeholders asked for clarity on the measurement of collateral values. We have provided clarification in the final guideline. Specifically, all collateral values reported should be presented after accounting for the central bank's haircuts.
Stakeholders noted that institutions may have various correspondent bank nostro accounts in USD, GBP, EUR, and other currencies that are used for commercial and retail activities, which have no material impact on overall intraday liquidity usage. Stakeholders asked that we consider a materiality threshold to allow some correspondent bank nostro accounts to be excluded from reporting. We have included a materiality threshold in the guideline. Specifically, all correspondent banks with gross payment flows greater than or equal to 5% of relevant currency payments should be included.
Stakeholders noted that including intraday credit to meet FX obligations in the list of intraday liquidity monitoring tools is unnecessary. Payments related to Continuous Linked Settlement (CLS) transactions are already reflected under “time-specific obligations” and the use of intraday credit received from correspondent banks is still captured as part of daily maximum intraday liquidity usage. We have removed intraday credit to meet FX obligations from the list of intraday liquidity monitoring tools. As per Guideline E-24 – Settlement Risk for Foreign Exchange Transactions, institutions should assess the impact of a correspondent bank restricting the provision of intraday credit on the institution’s ability to meet its FX obligations, particularly if cross-border collateral would need to be mobilized to facilitate settlement. However, institutions will not need to report this impact as part of the intraday liquidity monitoring tools.
Stakeholders requested clarity on the definition of unencumbered liquid assets (ULA). Stakeholders also requested that we clarify how the non-mortgage loan book (remaining portion not granted in business as usual) should be reported given it would likely be accessible under stress. We have included a definition for ULA in the final guideline. Specifically, ULA should include any assets that an institution can access and liquidate in the early hours of the day. This should include assets eligible as part of the standing liquidity facility (SLF), provided pricing conditions can be satisfied, including non-mortgage loan portfolios subject to a Bank of Canada 20% concentration limit. Non-SLF assets may also be included provided the institution has effective means to monetize them intraday. 
Intraday liquidity stress scenarios
Stakeholder feedback Our response
Stakeholders recommended the stress testing results be submitted less frequently. A longer time period would reduce month-to-month variability of results. Reduced reporting frequency also reduces some operational burden. We have modified the reporting requirements for stress testing such that stress testing results should be reported on a quarterly basis.
Stakeholders noted that based on various institutions’ business models, liquidity management, and risk culture, management actions can be understood in different ways. Stakeholders requested further clarification of the type of management actions expected in relation to the stress test scenarios. We have removed the “management actions” reporting section from quarterly stress testing. Instead, institutions should consider these actions as part of their development and testing of contingency funding plans and/or recovery and resolution plans.
Stakeholders asked for clarity on who the term “counterparty” refers to. The draft guideline states that a counterparty stress results where an institution is unable to rely on incoming payments from the stressed counterparty. There are varied interpretations on whether counterparty refers to the bank’s actual counterparty (from a credit perspective) or whether it refers to other direct participants in the payment system (e.g., Lynx or Fedwire) who may be settling payments on that counterparty’s behalf. We have defined counterparties as other institutions that are direct participants in the payment systems. We have also reduced the reporting requirements such that institutions only need to report their top counterparty rather than their top three counterparties.
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