Date: January 31, 2014
Issue: Regulatory Reform, Capital Formation
To: Board of Governors of the Federal Reserve, Federal Deposit Insurance Corporation, Office of the Comptroller of the Currency
Filing Type: Regulatory
Description: Joint comment letter to banking regulators addressing corporate treasurers' concerns with respect to the liquidity coverage ratio proposal issued by the regulators late last year. Applying a 100% outflow amount to undrawn credit commitments under bank customer securitization credit facilities could result in increased pricing of these facilities or reduce the availability of these facilities.