SIFMA Comment on Need for Extension of SLR Exclusion

Washington, D.C., February 23, 2021 – SIFMA today submitted a comment letter to the Federal Reserve System regarding the need to extend the interim final rule (IFR) for bank holding companies that provides a temporary exclusion of U.S. Treasury securities and deposits at the Federal Reserve Banks from the Supplementary Leverage Ratio (SLR).

“Banking organizations have played a pivotal role in market stability by extending credit, accepting deposits, and intermediating the capital markets throughout the cycle. The extension of the IFR is critical to the continued ability of banking organizations to continue accepting deposits and acting as intermediaries in the U.S. Treasury market,” the letter states. “Additionally, it is crucially important that the Federal Reserve communicate their intensions regarding the IFR in the very near future to prevent any unnecessary disruptions.”

Projections for the growth of the Federal Reserve’s balance sheet, future fiscal stimulus, and forward Treasury issuance, will result in firms’ SLR requirements becoming more binding. This reduced balance sheet capacity may impact future bank decision making regarding accepting deposits and acting as intermediaries in the U.S. Treasury market. This risks migration of some of this activity to the unregulated non-bank sector and may impact the smooth function and stability of the Treasury markets.

The full comment letter, which was also signed by the Financial Services Forum (FSF) and the American Bankers Association (ABA), expands on these views and can be found here.


SIFMA is the leading trade association for broker-dealers, investment banks and asset managers operating in the U.S. and global capital markets. On behalf of our industry’s nearly 1 million employees, we advocate for legislation, regulation and business policy, affecting retail and institutional investors, equity and fixed income markets and related products and services. We serve as an industry coordinating body to promote fair and orderly markets, informed regulatory compliance, and efficient market operations and resiliency. We also provide a forum for industry policy and professional development. SIFMA, with offices in New York and Washington, D.C., is the U.S. regional member of the Global Financial Markets Association (GFMA). For more information, visit