On October 30, the OCC and
FDIC proposed substantively the same
liquidity rule as the proposal approved by the
Fed on October 24. That
proposal developed by the three agencies applies to: (i) banking
organizations with $250 billion consolidated
assets; (ii) banking organizations with $10
billion in on-balance sheet foreign
exposure; (iii) systemically important,
non-bank financial institutions that do not have
substantial insurance subsidiaries or substantial insurance
operations; and (iv) bank and savings association subsidiaries
thereof that have total consolidated assets of $10
billion (covered institutions). The
proposed rule does not apply to community
banks.
Covered institutions would be required to maintain a specified
level of high-quality liquid assets such as central bank reserves,
government and Government Sponsored Enterprise securities and
corporate debt securities that can be converted easily into
cash. Under the proposal, a covered institution
