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TCH Comments on Basel Intraday Liquidity Proposal

The Clearing House Association filed an industry comment letter with the Basel Committee on its recent consultative document on monitoring indicators for intraday liquidity management. The letter raised concerns over whether or not the use of the proposed indicators for monitoring intraday liquidity will allow supervisors to have a complete understanding of how banks manage intraday liquidity including peak flows and govern the overall payments process. Additionally, the industry believes that the current proposal lacks clarity with respect to purpose, scope, cost and individual measurements.