SIFMA and other associations provide comments to the Office of the Comptroller of the Currency (OCC), the Board of Governors of the Federal Reserve System (Federal Reserve) and the Federal Deposit Insurance Corporation (the FDIC and, collectively, the Agencies), joint proposal, Liquidity Coverage Ratio: Liquidity Risk Measurement, Standards, and Monitoring (the U.S. Proposal).

In connection with the international liquidity standards (Basel LCR) published by the Basel Committee on Banking Supervision (BCBS) the notice proposes rules that would implement the liquidity coverage ratio (LCR) for banking organizations that are mandatorily subject to the advanced approaches risk-based capital rules, their respective consolidated subsidiary depository institutions with total consolidated assets greater than $10 billion, and nonbank financial companies designated by the Financial Stability Oversight Council (FSOC) for supervision by the Federal Reserve that do not have substantial insurance activities

The groups believe that the Basel LCR strikes an appropriate balance between accurately capturing liquidity risk and the concerns raised by banks in their comments leading up to the Basel LCR with respect to, among others, the measurement of that risk and the scope of oversight and related compliance requirements. Consequently, the groups share concerns that the U.S. Proposal deviates so significantly from the Basel LCR.

SIFMA signed the letter with: The Clearing House Association L.L.C., the American Bankers Association, the Financial Services Roundtable, the Institute of International Bankers, the International Association of Credit Portfolio Managers and the Structured Finance Industry Group.