The proposed six-month extension of existing returns FSA 047 and FSA 048 is driven by problems with PRA 110.  We therefore urge the PRA to delay implementation of this new return.  A delay will give the regulator time to consider if data provided by other liquidity returns, such as the C.66.01, satisfies prudential needs.  If they do not, then we believe the PRA should consider removing some of the detail and complexity from, and reducing the frequency of, the PRA 110.

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