May 29, 2020

Via Electronic Submission

Ann E. Misback
Secretary
Board of Governors of the Federal Reserve System
20th Street and Constitution Avenue NW
Washington, DC, 20551

Re: Regulatory Capital Rule: Temporary Exclusion of U.S. Treasury Securities and Deposits at the Federal Reserve Banks from the Supplementary Leverage Ratio

Dear Ladies and Gentlemen:

The Securities Industry and Financial Markets Association (“SIFMA”)2 appreciates the opportunity to comment on the Board of Governors of the Federal Reserve System’s (the “Federal Reserve”) interim final rule providing a temporary exclusion from the Supplementary Leverage Ratio (“SLR”) for U.S. Treasury securities and deposits at the Federal Reserve Banks (the “IFR”).

We support the Federal Reserve’s strong and multifaceted response to the COVID-19 crisis, which poses unique and unprecedented challenges for communities, businesses, households and individuals. The Federal Reserve’s timely interventions, including through the establishment of emergency lending programs, have helped to contain the impact of economic and market disruptions associated with the COVID-19 crisis. The IFR complements these wider efforts and increases the capacity of large U.S. bank holding companies and intermediate holding companies of foreign banks to extend credit and make markets at this critical time. Accordingly, we support the IFR.