TCH 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. The letter notes that such guidance is important given the substantial challenges that banks would face in implementing the LCR Proposal’s daily calculation requirement after the final rule is issued and before the effective implementation date. The letter also requests that any such delay should extend, at a minimum, to twelve months following the end of the calendar year in which the Agencies publish the final LCR.
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