Fed Amends Liquidity Rules To Permit Limited Inclusion Of State And Municipal Securities

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On April 1, 2016, the Federal Reserve Board (Board) issued a final rule that expands eligible "high-quality liquid assets" (HQLA) for the Basel III liquidity coverage ratio.
United States Finance and Banking
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On April 1, 2016, the Federal Reserve Board (Board) issued a final rule that expands eligible "high-quality liquid assets" (HQLA) for the Basel III liquidity coverage ratio (LCR). This final rule allows investment grade, general obligation US state and municipal bonds to be included as Level 2B HQLA up to certain levels if they meet the same liquidity criteria that currently apply to corporate debt securities. (For a description of those criteria, please refer to our earlier Legal Update.)

Notably, the final rule did not adopt the Board's previously proposed limitations on:

  1. the amount of permissible municipal bonds with the same CUSIP number (but it retains the proposed 2x trading volume per issuer limit and the 5 percent of overall HQLA cap); and
  2. inclusion of insured municipal bonds (however, under the final rule the underlying municipal bond must meet the rule's requirements for inclusion without regard to the insurance).

The Board's final rule applies only to Board-supervised covered institutions that are subject to the LCR (i.e., generally US bank holding companies with at least $50 billion in assets), and it is not clear whether the OCC and FDIC will adopt similar rules.

Originally published 5 April 2016

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Fed Amends Liquidity Rules To Permit Limited Inclusion Of State And Municipal Securities

United States Finance and Banking
Contributor
Mayer Brown is a distinctively global law firm, uniquely positioned to advise the world’s leading companies and financial institutions on their most complex deals and disputes. We have deep experience in high-stakes litigation and complex transactions across industry sectors, including our signature strength, the global financial services industry.
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