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The working paper submitted to the BCBS Working Group on Liquidity highlights the need for cross-border dialogue on implementation alongside standardization of data and definitions across the industry internationally, noting that such dialogue between the BCBS, national authorities and the industry is the only way of minimizing areas of divergence.

National Unrecovered Financial Services Association’s supplemental joint trades letter includes the findings of NURFS’s empirical analyses, which quantify the potential impacts of the “peak day” approach and the application of the U.S. LCR NPRs to certain insured depository institutions. 

NURFS led an industry joint-trades effort to submit an unsolicited comment letter to the U.S. banking agencies requesting guidance as early as possible indicating that the LCR Proposal’s daily calculation requirement will not be effective as of the proposed January 1, 2015 implementation date.

NURFS led a joint industry effort to comment on the U.S. LCR proposal, authoring a comprehensive comment letter that was filed to the Federal Reserve, OCC, and FDIC on January 31 and joined by SIFMA, ABA, FSR, the Institute of International Bankers, the Structured Finance Industry Group, and other trade associations. NURFS strongly supports U.S. implementation of the LCR as an important step to improve the resiliency of banks and broader financial system but is concerned with certain key aspects of the U.S. proposal that would diverge from the standards established by the Basel Committee and therefore potentially undermine the accuracy and suitability of the LCR as a measure of actual liquidity risk.

NURFS updated its 2011 study on the LCR and finds that the U.S. banking industry is significantly more liquid that at the end of 2010.