Date: February 2, 2016

Issue: Federal Reserve 

To: Mr. Robert de V. Frierson, Secretary, Board of Governors of the Federal Reserve

Filing Type: Regulatory

Description: In addition to the concerns raised in our previous comment letter on the liquidity coverage ratio, we wish to raise a number of concerns relating to the Federal Reserve’s proposed rule on public disclosure requirements for the liquidity coverage ratio (the “Proposed Rule”). Broadly, we believe that several improvements can be made to the rule to improve its workability and consistency with similar disclosure requirements under regulatory disclosures required under the Basel III capital rules to help minimize the potential for disruptive market responses.

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