©P1NC January 31, 2014 Via Electronic Mail Robert de V. Frierson, Secretary Legislative and Regulatory Activities Board of Governors of the Federal Reserve Division System Office of the Comptroller of the Currency 20th Street and Constitution Avenue, NW 400 7th Street, SW Washington, DC 20551 Washington, DC 20219
[email protected] [email protected] Docket No. R-1466 Docket ID OCC-2013-0016 RIN 7100 AE-03 RIN 1557 AD 74 Robert E. Feldman, Executive Secretary Attention: Comments/Legal ESS Federal Deposit Insurance Corporation 550 1 7th Street, NW Washington, DC 20429
[email protected] RIN 3064-AE04 Re: Liquidity Coverage Ratio: Liquidity Risk Measurement, Standards, and Monitoring — Notice of Proposed Rulemaking ("Proposal")1 Ladies and Gentlemen: The PNC Financial Services Group, Inc. ("PNC") appreciates the opportunity to provide comments on the Proposal, which was issued by the Board of Governors of the Federal Reserve System (the "Federal Reserve"), the Federal Deposit Insurance Corporation ("FDIC"), and the Office of the Comptroller of the Currency ("OCC") (together the "Agencies"). The Proposal would implement the liquidity coverage ratio framework (the "LCR Framework") established by the Basel Committee on Bank Supervision ("BCBS") in the United States.2 Under the proposal, the Agencies would establish a liquidity coverage ratio (the "Full LCR") for banking organizations with $250 billion or more in total consolidated assets or $10 billion or more in on-balance sheet 1 Liquidity Coverage Ratio: Liquidity Risk Measurement, Standards, and Monitoring, 78 Fed. Reg. 71,818 (Nov. 29, 2013). 2 Basel Committee on Banking Supervision, Basel III: The Liquidity Coverage Ratio and liquidity risk monitoring tools (revised January 2013), available at http://www.bis.org/publ/bcbs238.pdf.