The groups also asked the agencies to notify banks as early as possible if an extension is offered, “thus allowing them to allocate limited resources appropriately among a growing number of competing regulatory priorities.”
A delay in the daily reporting requirement would not mean banks are unable to monitor their liquidity positions, the groups said.
Banking organizations … currently conduct regular and robust monitoring, reporting, and forecasting of liquidity positions and indicia of liquidity risk. However, these existing liquidity monitoring systems and related reports, even where available on a daily basis, are not currently tailored to the detailed requirements contained in the [LCR] proposal.
Under the proposed ratio, internationally active banking organizations with over $250 billion in assets and certain subsidiaries would have to hold high-quality liquid assets against the largest “net cumulative cash outflow as of the end of the 30-day period.” A modified LCR would apply to holding companies with $50 billion in assets or more that are not internationally active, requiring banks to hold HQLA based on a 21-day stress scenario.
Read the letter.