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Article July 14, 2025

Post-SVB Liquidity Rules Are Coming, But Don't Expect Clarity

Post-SVB Liquidity Rules Are Coming, But Don't Expect Clarity

Shahab Khan, Head of Liquidity Policy, HSBC USALinkedIn profile for Shahab Khan

In the wake of SVB’s collapse, liquidity regulation in the U.S. is under intense scrutiny. Delays in reform mask a shift toward tougher liquidity standards, greater reliance on central bank facilities, and a rethinking of what counts as a safe asset.

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In the aftermath of Silicon Valley Bank’s collapse, liquidity risk has become the focal point of regulatory debate – but don’t mistake urgency for clarity.

What emerged from a recent industry session was a strong consensus: SVB’s failure accelerated scrutiny, but the underlying regulatory momentum was already in motion. Now, financial institutions are navigating a shifting landscape of expectations, uncertainty, and evolving supervisory tone.

The session, set against a volatile political and regulatory backdrop, highlighted a paradox.

While the Biden administration had indicated late last year that regulatory reform would intensify, the new, more deregulatory administration has slowed implementation without scrapping the agenda.

The delay in execution has bought time, but not relief. Liquidity reforms are still coming – just not on a predictable schedule.

Capital adequacy may still dominate headlines, but as the speaker emphasized, SVB collapsed because of liquidity, not capital, failures.

The core issue was not about long-term solvency, but about institutions’ ability to withstand short-term shocks.

Regulators are now turning their attention to refining the Liquidity Coverage Ratio and may begin demanding more granular data on one-to-seven-day outflows. This short-term horizon is increasingly seen as the weak link in otherwise sound liquidity frameworks.

Perhaps the most controversial idea floated was a potential shift in what qualifies as high-quality liquid assets.

Regulators are reportedly exploring a preference for reserves held directly at the Federal Reserve, instead of U.S. Treasuries.

While the rationale remains vague, this move could ripple through the Treasury market, impacting liquidity and pricing dynamics, especially for primary dealers.

The conversation hinted at growing unease among policymakers about over-reliance on market-based liquidity during stress events.

In tandem, there’s a growing regulatory push to normalize the use of central bank liquidity facilities, particularly the Fed’s discount window and the FHLB system.

This push stops short of a mandate, but the tone is unmistakable: these mechanisms should no longer be treated as last-resort options.

Still, operational inefficiencies, including auction mechanics and approval delays, continue to deter banks from leaning on them when they matter most.

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