The Clearing House Association filed a supplemental joint trades comment letter related to issues raised during the prior joint trades interagency meetings on the original U.S. LCR NPRs. The letter includes the findings of TCH’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. The letter also addresses: (i) the accelerated implementation, (ii) the treatment of collateralized corporate trust account deposits, (iii) the definition of “regulated financial company”, and (iv) the treatment of collateral outflow amounts related to derivative transactions, under the U.S. LCR NPRS. Separately, on June 30, TCH joined a joint trades letter regarding the treatment of municipal securities as HQLA under the U.S. LCR NPRs.
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