Debevoise & Plimpton

The Liquidity Coverage Ratio proposal — questions and answers

On 24 October 2013, the Federal Reserve, followed on 30 October by the Federal Deposit Insurance Corporation (FDIC) and the Office of the Comptroller of the Currency (OCC), released a proposed rule that would apply a Liquidity Coverage Ratio (LCR) to certain US banking organisations.

Currently, US banking regulations do not impose a quantitative liquidity requirement on banking organisations but instead require the use of risk management and other tools to manage liquidity needs. The proposed rule would for the first time require banking organisations to meet minimum quantitative liquidity standards and thus represents an important milestone in the post-crisis regulatory reform process.

The proposed rule is broadly consistent with the LCR finalised earlier this year by the Basel Committee on Banking Supervision but, as with US regulators’ implementation of other Basel III initiatives, it is in certain key respects more stringent than the international standard…

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