The Clearing House (TCH) submitted a comment letter to the Fed, jointly with the ABA, SIFMA and FSR, in response to U.S. proposal to implement public disclosure requirements for the LCR. The letter expresses support of the LCR as a supervisory tool, but as previously stated by TCH, expresses concern that granular disclosure of the LCR’s components may increase the very types of risks to systemic stability and to financial institutions that the LCR is designed to mitigate, and may constrain banking organizations’ ability to respond to severe market conditions or facilitate anti-competitive and potentially predatory behavior. The letter requests that the LCR disclosure be limited to a bank’s: (i) LCR, (ii) aggregate HQLA, (iii) aggregate inflows, and (iv) aggregate outflows. Additionally, the letter also requests that banks be given a minimum of 90 days after publication of the final rule and response to relevant FAQs, to prepare and test systems and processes for implementation of the data collection required by the proposal.