BPI and Coalition of Trades Comment on Fed Proposal to Revise the Complex Institution Liquidity Monitoring Report

To Whom it May Concern:

The Bank Policy Institute, the Securities Industry and Financial Markets Association, the American Bankers Association, the Institute of International Bankers, and the Financial Services Forum (collectively, the Associations)[1] appreciate the opportunity to comment on the proposal by the Board of Governors of the Federal Reserve System to revise the Complex Institution Liquidity Monitoring Report (FR 2052a)[2] and will submit a separate comprehensive comment letter discussing technical issues and questions on the proposed changes prior to the comment deadline. The purpose of this letter is to inform the Federal Reserve promptly of the infeasibility of respondent firms implementing the proposed changes by the stated effective date. Given the extensive systems modifications that would be required and substantive interpretation questions raised by the proposal regarding the Net Stable Funding Ratio requirement, we ask that the Federal Reserve extend the proposed implementation timeline to no earlier than April 1, 2022, for those proposed FR 2052a items necessary for the Federal Reserve to calculate the NSFR, and to no earlier than October 1, 2022, for the remaining changes to the FR 2052a.[3] This staged timeline would allow firms to prioritize the implementation of new or revised data elements necessary to calculate the NSFR, with items unrelated to the calculation of the NSFR becoming effective at a later date.[4]

To read the full comment letter, click here, or click on the download button below.

[1] See Appendix 1 for descriptions of the Associations.

[2] 86 Fed. Reg. 16365 (March 29, 2021).

[3] Dates provided throughout this letter assume that final forms and instructions (including technical instructions) will be provided by June 30, 2021, providing respondents with at least 9-15 months to prepare for implementation of the changes to the FR 2052a.

[4] Given the number of revisions, firms are in the process of completing their initial analyses. Additional thoughts with respect to the implementation timeline for 2052a changes for firms that are not subject to the NSFR will be contained in our forthcoming comprehensive comment letter on the proposal.