The Clearing House Association joined by ABASA submitted a comment letter expressing substantial concerns that the Volcker Rule may significantly inhibit the ability of banking organizations to engage in asset-liability-management (ALM) activities that are essential to the safe and sound management of the risks that arise from the core business of banking. The rule’s broad definition of trading account would cause important ALM activities to fall within the prohibition on proprietary trading to the detriment of both banking organizations and financial markets. The associations urge the agencies to replace the exclusion provided for liquidity management activities with an exclusion that would cover transactions in furtherance of a banking organization’s bona fide ALM activities.