Legislative and Regulatory Activities Division
Office of the Comptroller of the Currency
400 7th Street SW, Suite 3E-218
Washington, DC 20219
Docket ID OCC-2018-0013 

Ann E. Misback, Secretary
Board of Governors of the Federal Reserve System
20th Street and Constitution Avenue NW
Washington, DC 20551
Docket No. R-1616

Robert E. Feldman, Executive Secretary
Attention: Comments/Legal ESS
Federal Deposit Insurance Corporation
550 17th Street NW
Washington, DC 20429
FDIC RIN 3064-AE77

Transmitted via the Federal eRulemaking Portal

To Whom It May Concern:

SIFMA1 is pleased to comment on the recent interim final rule on “Liquidity Coverage Ratio: Treatment of Certain Municipal Obligations as High-Quality Liquid Assets” (the “Rule”) published by the Office of the Comptroller of the Currency, the Board of Governors of the Federal Reserve System, and the Federal Deposit Insurance Corporation (together the “Agencies”).
SIFMA believes the Rule represents a sound regulatory implementation of Section 403 of the Economic Growth, Regulatory Relief, and Consumer Protection Act (PL 115-174, the “Act”). Section 403 of the Act requires the Agencies to amend their Liquidity Coverage Ratio rules to provide Level 2B High Quality Liquid Asset (“HQLA”) treatment for municipal securities that are investment grade and liquid and readily marketable. The Rule effectively carries out this provision without applying any restrictions on municipal securities as HQLA that do not also apply to other Level 2B HQLA. We believe the Rule is consistent with congressional intent and effectively implements the new statute. SIFMA fully supports the interim final Rule and we thank the principals and staff of the Agencies for their work on this issue.

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