SIFMA and the Structured Finance Industry Group (SFIG) provide comments to the Office of the Comptroller of the Currency (OCC), the Board of Governors of the Federal Reserve, and the Federal Deposit Insurance Corporation (FDIC) on the proposed liquidity coverage ratio (LCR) regulations issued by the Agencies, Liquidity Coverage Ratio: Liquidity Risk Measurement, Standards and Monitoring.

The Associations support the Agencies’ efforts to improve the banking sector’s ability to absorb shocks from financial and economic stress and the Agencies’ proposal to implement an LCR requirement that is generally consistent with the Basel LCR. However, the Associations believe that LCR regulations should recognize that traditional securitization activities are: (i) an essential source of core funding to the real economy and (ii) an important part of a bank’s liquidity management strategy. With the adjustments the Associations propose, the Agencies could sufficiently recognize these realities while still meeting their stated goals and objectives for enhanced liquidity standards.