Regulatory Capital Rules: Regulatory Capital, Implementation of Basel III, Capital Adequacy, Transition Provisions, Prompt Corrective Action, Standardized Approach for Risk-weighted Assets, Market Discipline and Disclosure Requirements, Advanced Approaches Risk-Based Capital Rule, and Market Risk Capital Rule, 62017-62291 [2013-21653]
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Vol. 78
Friday,
No. 198
October 11, 2013
Part II
Department of the Treasury
Office of the Comptroller of the Currency
12 CFR Parts 3, 5, 6, et al.
Federal Reserve System
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12 CFR Parts 208, 217, and 225
Regulatory Capital Rules: Regulatory Capital, Implementation of Basel III,
Capital Adequacy, Transition Provisions, Prompt Corrective Action,
Standardized Approach for Risk-weighted Assets, Market Discipline and
Disclosure Requirements, Advanced Approaches Risk-Based Capital Rule,
and Market Risk Capital Rule; Final Rule
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Federal Register / Vol. 78, No. 198 / Friday, October 11, 2013 / Rules and Regulations
DEPARTMENT OF THE TREASURY
Office of the Comptroller of the
Currency
12 CFR Parts 3, 5, 6, 165, and 167
[Docket ID OCC–2012–0008]
RIN 1557–AD46
FEDERAL RESERVE SYSTEM
12 CFR Parts 208, 217, and 225
[Docket No. R–1442; Regulations H, Q,
and Y]
RIN 7100–AD 87
Regulatory Capital Rules: Regulatory
Capital, Implementation of Basel III,
Capital Adequacy, Transition
Provisions, Prompt Corrective Action,
Standardized Approach for Riskweighted Assets, Market Discipline
and Disclosure Requirements,
Advanced Approaches Risk-Based
Capital Rule, and Market Risk Capital
Rule
Office of the Comptroller of the
Currency, Treasury; and the Board of
Governors of the Federal Reserve
System.
ACTION: Final rule.
AGENCY:
The Office of the Comptroller
of the Currency (OCC) and Board of
Governors of the Federal Reserve
System (Board), are adopting a final rule
that revises their risk-based and leverage
capital requirements for banking
organizations. The final rule
consolidates three separate notices of
proposed rulemaking that the OCC,
Board, and FDIC published in the
Federal Register on August 30, 2012,
with selected changes. The final rule
implements a revised definition of
regulatory capital, a new common
equity tier 1 minimum capital
requirement, a higher minimum tier 1
capital requirement, and, for banking
organizations subject to the advanced
approaches risk-based capital rules, a
supplementary leverage ratio that
incorporates a broader set of exposures
in the denominator. The final rule
incorporates these new requirements
into the agencies’ prompt corrective
action (PCA) framework. In addition,
the final rule establishes limits on a
banking organization’s capital
distributions and certain discretionary
bonus payments if the banking
organization does not hold a specified
amount of common equity tier 1 capital
in addition to the amount necessary to
meet its minimum risk-based capital
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SUMMARY:
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requirements. Further, the final rule
amends the methodologies for
determining risk-weighted assets for all
banking organizations, and introduces
disclosure requirements that would
apply to top-tier banking organizations
domiciled in the United States with $50
billion or more in total assets. The final
rule also adopts changes to the agencies’
regulatory capital requirements that
meet the requirements of section 171
and section 939A of the Dodd-Frank
Wall Street Reform and Consumer
Protection Act.
The final rule also codifies the
agencies’ regulatory capital rules, which
have previously resided in various
appendices to their respective
regulations, into a harmonized
integrated regulatory framework. In
addition, the OCC is amending the
market risk capital rule (market risk
rule) to apply to Federal savings
associations, and the Board is amending
the advanced approaches and market
risk rules to apply to top-tier savings
and loan holding companies domiciled
in the United States, except for certain
savings and loan holding companies
that are substantially engaged in
insurance underwriting or commercial
activities, as described in this preamble.
DATES: Effective date: January 1, 2014,
except that the amendments to
Appendixes A, B and E to 12 CFR Part
208, 12 CFR 225.1, and Appendixes D
and E to Part 225 are effective January
1, 2015, and the amendment to
Appendix A to 12 CFR Part 225 is
effective January 1, 2019. Mandatory
compliance date: January 1, 2014 for
advanced approaches banking
organizations that are not savings and
loan holding companies; January 1,
2015 for all other covered banking
organizations.
FOR FURTHER INFORMATION CONTACT:
OCC: Margot Schwadron, Senior Risk
Expert, (202) 649–6982; David Elkes,
Risk Expert, (202) 649–6984; Mark
Ginsberg, Risk Expert, (202) 649–6983,
Capital Policy; or Ron Shimabukuro,
Senior Counsel; Patrick Tierney, Special
Counsel; Carl Kaminski, Senior
Attorney; or Kevin Korzeniewski,
Attorney, Legislative and Regulatory
Activities Division, (202) 649–5490,
Office of the Comptroller of the
Currency, 400 7th Street SW.,
Washington, DC 20219.
Board: Anna Lee Hewko, Deputy
Associate Director, (202) 530–6260;
Thomas Boemio, Manager, (202) 452–
2982; Constance M. Horsley, Manager,
(202) 452–5239; Juan C. Climent, Senior
Supervisory Financial Analyst, (202)
872–7526; or Elizabeth MacDonald,
Senior Supervisory Financial Analyst,
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(202) 475–6316, Capital and Regulatory
Policy, Division of Banking Supervision
and Regulation; or Benjamin
McDonough, Senior Counsel, (202) 452–
2036; April C. Snyder, Senior Counsel,
(202) 452–3099; Christine Graham,
Senior Attorney, (202) 452–3005; or
David Alexander, Senior Attorney, (202)
452–2877, Legal Division, Board of
Governors of the Federal Reserve
System, 20th and C Streets NW.,
Washington, DC 20551. For the hearing
impaired only, Telecommunication
Device for the Deaf (TDD), (202) 263–
4869.
SUPPLEMENTARY INFORMATION:
Table of Contents
I. Introduction
II. Summary of the Three Notices of Proposed
Rulemaking
A. The Basel III Notice of Proposed
Rulemaking
B. The Standardized Approach Notice of
Proposed Rulemaking
C. The Advanced Approaches Notice of
Proposed Rulemaking
III. Summary of General Comments on the
Basel III Notice of Proposed Rulemaking
and on the Standardized Approach
Notice of Proposed Rulemaking;
Overview of the Final Rule
A. General Comments on the Basel III
Notice of Proposed Rulemaking and on
the Standardized Approach Notice of
Proposed Rulemaking
1. Applicability and Scope
2. Aggregate Impact
3. Competitive Concerns
4. Costs
B. Comments on Particular Aspects of the
Basel III Notice of Proposed Rulemaking
and on the Standardized Approach
Notice of Proposed Rulemaking
1. Accumulated Other Comprehensive
Income
2. Residential Mortgages
3. Trust Preferred Securities for Smaller
Banking Organizations
4. Insurance Activities
C. Overview of the Final Rule
D. Timeframe for Implementation and
Compliance
IV. Minimum Regulatory Capital Ratios,
Additional Capital Requirements, and
Overall Capital Adequacy
A. Minimum Risk-Based Capital Ratios and
Other Regulatory Capital Provisions
B. Leverage Ratio
C. Supplementary Leverage Ratio for
Advanced Approaches Banking
Organizations
D. Capital Conservation Buffer
E. Countercyclical Capital Buffer
F. Prompt Corrective Action Requirements
G. Supervisory Assessment of Overall
Capital Adequacy
H. Tangible Capital Requirement for
Federal Savings Associations
V. Definition of Capital
A. Capital Components and Eligibility
Criteria for Regulatory Capital
Instruments
1. Common Equity Tier 1 Capital
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2. Additional Tier 1 Capital
3. Tier 2 Capital
4. Capital Instruments of Mutual Banking
Organizations
5. Grandfathering of Certain Capital
Instruments
6. Agency Approval of Capital Elements
7. Addressing the Point of Non-Viability
Requirements Under Basel III
8. Qualifying Capital Instruments Issued by
Consolidated Subsidiaries of a Banking
Organization
9. Real Estate Investment Trust Preferred
Capital
B. Regulatory Adjustments and Deductions
1. Regulatory Deductions From Common
Equity Tier 1 Capital
a. Goodwill and Other Intangibles (Other
Than Mortgage Servicing Assets)
b. Gain-on-sale Associated With a
Securitization Exposure
c. Defined Benefit Pension Fund Net Assets
d. Expected Credit Loss That Exceeds
Eligible Credit Reserves
e. Equity Investments in Financial
Subsidiaries
f. Deduction for Subsidiaries of Savings
Associations That Engage in Activities
That Are Not Permissible for National
Banks
2. Regulatory Adjustments to Common
Equity Tier 1 Capital
a. Accumulated Net Gains and Losses on
Certain Cash-Flow Hedges
b. Changes in a Banking Organization’s
Own Credit Risk
c. Accumulated Other Comprehensive
Income
d. Investments in Own Regulatory Capital
Instruments
e. Definition of Financial Institution
f. The Corresponding Deduction Approach
g. Reciprocal Crossholdings in the Capital
Instruments of Financial Institutions
h. Investments in the Banking
Organization’s Own Capital Instruments
or in the Capital of Unconsolidated
Financial Institutions
i. Indirect Exposure Calculations
j. Non-Significant Investments in the
Capital of Unconsolidated Financial
Institutions
k. Significant Investments in the Capital of
Unconsolidated Financial Institutions
That Are Not in the Form of Common
Stock
l. Items Subject to the 10 and 15 Percent
Common Equity Tier 1 Capital Threshold
Deductions
m. Netting of Deferred Tax Liabilities
Against Deferred Tax Assets and Other
Deductible Assets
3. Investments in Hedge Funds and Private
Equity Funds Pursuant to Section 13 of
the Bank Holding Company Act
VI. Denominator Changes Related to the
Regulatory Capital Changes
VII. Transition Provisions
A. Transitions Provisions for Minimum
Regulatory Capital Ratios
B. Transition Provisions for Capital
Conservation and Countercyclical
Capital Buffers
C. Transition Provisions for Regulatory
Capital Adjustments and Deductions
1. Deductions for Certain Items Under
Section 22(a) of the Final Rule
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2. Deductions for Intangibles Other Than
Goodwill and Mortgage Servicing Assets
3. Regulatory Adjustments Under Section
22(b)(1) of the Final Rule
4. Phase-out of Current Accumulated Other
Comprehensive Income Regulatory
Capital Adjustments
5. Phase-out of Unrealized Gains on
Available for Sale Equity Securities in
Tier 2 Capital
6. Phase-in of Deductions Related to
Investments in Capital Instruments and
to the Items Subject to the 10 and 15
Percent Common Equity Tier 1 Capital
Deduction Thresholds (Sections 22(c)
and 22(d)) of the Final Rule
D. Transition Provisions for Non-qualifying
Capital Instruments
1. Depository Institution Holding
Companies With Less Than $15 Billion
in Total Consolidated Assets as of
December 31, 2009 and 2010 Mutual
Holding Companies
2. Depository Institutions
3. Depository Institution Holding
Companies With $15 Billion or More in
Total Consolidated Assets as of
December 31, 2009 That Are Not 2010
Mutual Holding Companies
4. Merger and Acquisition Transition
Provisions
5. Phase-out Schedule for Surplus and
Non-Qualifying Minority Interest
VIII. Standardized Approach for Riskweighted Assets
A. Calculation of Standardized Total Riskweighted Assets
B. Risk-weighted Assets for General Credit
Risk
1. Exposures to Sovereigns
2. Exposures to Certain Supranational
Entities and Multilateral Development
Banks
3. Exposures to Government-sponsored
Enterprises
4. Exposures to Depository Institutions,
Foreign Banks, and Credit Unions
5. Exposures to Public-sector Entities
6. Corporate Exposures
7. Residential Mortgage Exposures
8. Pre-sold Construction Loans and
Statutory Multifamily Mortgages
9. High-volatility Commercial Real Estate
10. Past-Due Exposures
11. Other Assets
C. Off-balance Sheet Items
1. Credit Conversion Factors
2. Credit-Enhancing Representations and
Warranties
D. Over-the-Counter Derivative Contracts
E. Cleared Transactions
1. Definition of Cleared Transaction
2. Exposure Amount Scalar for Calculating
for Client Exposures
3. Risk Weighting for Cleared Transactions
4. Default Fund Contribution Exposures
F. Credit Risk Mitigation
1. Guarantees and Credit Derivatives
a. Eligibility Requirements
b. Substitution Approach
c. Maturity Mismatch Haircut
d. Adjustment for Credit Derivatives
Without Restructuring as a Credit Event
e. Currency Mismatch Adjustment
f. Multiple Credit Risk Mitigants
2. Collateralized Transactions
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a. Eligible Collateral
b. Risk-management Guidance for
Recognizing Collateral
c. Simple Approach
d. Collateral Haircut Approach
e. Standard Supervisory Haircuts
f. Own Estimates of Haircuts
g. Simple Value-at-Risk and Internal
Models Methodology
G. Unsettled Transactions
H. Risk-weighted Assets for Securitization
Exposures
1. Overview of the Securitization
Framework and Definitions
2. Operational Requirements
a. Due Diligence Requirements
b. Operational Requirements for
Traditional Securitizations
c. Operational Requirements for Synthetic
Securitizations
d. Clean-up Calls
3. Risk-weighted Asset Amounts for
Securitization Exposures
a. Exposure Amount of a Securitization
Exposure
b. Gains-on-sale and Credit-enhancing
Interest-only Strips
c. Exceptions Under the Securitization
Framework
d. Overlapping Exposures
e. Servicer Cash Advances
f. Implicit Support
4. Simplified Supervisory Formula
Approach
5. Gross-up Approach
6. Alternative Treatments for Certain Types
of Securitization Exposures
a. Eligible Asset-backed Commercial Paper
Liquidity Facilities
b. A Securitization Exposure in a Secondloss Position or Better to an AssetBacked Commercial Paper Program
7. Credit Risk Mitigation for Securitization
Exposures
8. Nth-to-default Credit Derivatives
IX. Equity Exposures
A. Definition of Equity Exposure and
Exposure Measurement
B. Equity Exposure Risk Weights
C. Non-significant Equity Exposures
D. Hedged Transactions
E. Measures of Hedge Effectiveness
F. Equity Exposures to Investment Funds
1. Full Look-Through Approach
2. Simple Modified Look-Through
Approach
3. Alternative Modified Look-Through
Approach
X. Insurance-related Activities
A. Policy Loans
B. Separate Accounts
C. Additional Deductions—Insurance
Underwriting Subsidiaries
XI. Market Discipline and Disclosure
Requirements
A. Proposed Disclosure Requirements
B. Frequency of Disclosures
C. Location of Disclosures and Audit
Requirements
D. Proprietary and Confidential
Information
E. Specific Public Disclosure Requirements
XII. Risk-Weighted Assets—Modifications to
the Advanced Approaches
A. Counterparty Credit Risk
1. Recognition of Financial Collateral
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a. Financial Collateral
b. Revised Supervisory Haircuts
2. Holding Periods and the Margin Period
of Risk
3. Internal Models Methodology
a. Recognition of Wrong-Way Risk
b. Increased Asset Value Correlation Factor
4. Credit Valuation Adjustments
a. Simple Credit Valuation Adjustment
Approach
b. Advanced Credit Valuation Adjustment
Approach
5. Cleared Transactions (Central
Counterparties)
6. Stress Period for Own Estimates
B. Removal of Credit Ratings
1. Eligible Guarantor
2. Money Market Fund Approach
3. Modified Look-through Approaches for
Equity Exposures to Investment Funds
C. Revisions to the Treatment of
Securitization Exposures
1. Definitions
2. Operational Criteria for Recognizing
Risk Transference in Traditional
Securitizations
3. The Hierarchy of Approaches
4. Guarantees and Credit Derivatives
Referencing a Securitization Exposure
5. Due Diligence Requirements for
Securitization Exposures
6. Nth-to-Default Credit Derivatives
D. Treatment of Exposures Subject to
Deduction
E. Technical Amendments to the Advanced
Approaches Rule
1. Eligible Guarantees and Contingent U.S.
Government Guarantees
2. Calculation of Foreign Exposures for
Applicability of the Advanced
Approaches—Insurance Underwriting
Subsidiaries
3. Calculation of Foreign Exposures for
Applicability of the Advanced
Approaches—Changes to Federal
Financial Institutions Examination
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4. Applicability of the Final Rule
5. Change to the Definition of Probability
of Default Related to Seasoning
6. Cash Items in Process of Collection
7. Change to the Definition of Qualifying
Revolving Exposure
8. Trade-related Letters of Credit
9. Defaulted Exposures That Are
Guaranteed by the U.S. Government
10. Stable Value Wraps
11. Treatment of Pre-Sold Construction
Loans and Multi-Family Residential
Loans
F. Pillar 3 Disclosures
1. Frequency and Timeliness of Disclosures
2. Enhanced Securitization Disclosure
Requirements
3. Equity Holdings That Are Not Covered
Positions
XIII. Market Risk Rule
XIV. Additional OCC Technical Amendments
XV. Abbreviations
XVI. Regulatory Flexibility Act
XVII. Paperwork Reduction Act
XVIII. Plain Language
XIX. OCC Unfunded Mandates Reform Act of
1995 Determinations
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I. Introduction
On August 30, 2012, the Office of the
Comptroller of the Currency (OCC) the
Board of Governors of the Federal
Reserve System (Board) (collectively,
the agencies), and the Federal Deposit
Insurance Corporation (FDIC) published
in the Federal Register three joint
notices of proposed rulemaking seeking
public comment on revisions to their
risk-based and leverage capital
requirements and on methodologies for
calculating risk-weighted assets under
the standardized and advanced
approaches (each, a proposal, and
together, the NPRs, the proposed rules,
or the proposals).1 The proposed rules,
in part, reflected agreements reached by
the Basel Committee on Banking
Supervision (BCBS) in ‘‘Basel III: A
Global Regulatory Framework for More
Resilient Banks and Banking Systems’’
(Basel III), including subsequent
changes to the BCBS’s capital standards
and recent BCBS consultative papers.2
Basel III is intended to improve both the
quality and quantity of banking
organizations’ capital, as well as to
strengthen various aspects of the
international capital standards for
calculating regulatory capital. The
proposed rules also reflect aspects of the
Basel II Standardized Approach and
other Basel Committee standards.
The proposals also included changes
consistent with the Dodd-Frank Wall
Street Reform and Consumer Protection
Act (the Dodd-Frank Act); 3 would apply
the risk-based and leverage capital rules
to top-tier savings and loan holding
companies (SLHCs) domiciled in the
United States; and would apply the
market risk capital rule (the market risk
rule) 4 to Federal and state savings
associations (as appropriate based on
trading activity).
The NPR titled ‘‘Regulatory Capital
Rules: Regulatory Capital,
Implementation of Basel III, Minimum
Regulatory Capital Ratios, Capital
Adequacy, Transition Provisions, and
1 77 FR 52792 (August 30, 2012); 77 FR 52888
(August 30, 2012); 77 FR 52978 (August 30, 2012).
2 Basel III was published in December 2010 and
revised in June 2011. The text is available at https://
www.bis.org/publ/bcbs189.htm. The BCBS is a
committee of banking supervisory authorities,
which was established by the central bank
governors of the G–10 countries in 1975. More
information regarding the BCBS and its
membership is available at https://www.bis.org/bcbs/
about.htm. Documents issued by the BCBS are
available through the Bank for International
Settlements Web site at https://www.bis.org.
3 Public Law 111–203, 124 Stat. 1376, 1435–38
(2010).
4 The agencies’ and the FDIC’s market risk rule is
at 12 CFR part 3, appendix B (OCC); 12 CFR parts
208 and 225, appendix E (Board); and 12 CFR part
325, appendix C (FDIC).
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Prompt Corrective Action’’ 5 (the Basel
III NPR), provided for the
implementation of the Basel III revisions
to international capital standards related
to minimum capital requirements,
regulatory capital, and additional
capital ‘‘buffer’’ standards to enhance
the resilience of banking organizations
to withstand periods of financial stress.
(Banking organizations include national
banks, state member banks, Federal
savings associations, and top-tier bank
holding companies domiciled in the
United States not subject to the Board’s
Small Bank Holding Company Policy
Statement (12 CFR part 225, appendix
C)), as well as top-tier savings and loan
holding companies domiciled in the
United States, except certain savings
and loan holding companies that are
substantially engaged in insurance
underwriting or commercial activities,
as described in this preamble.) The
proposal included transition periods for
many of the requirements, consistent
with Basel III and the Dodd-Frank Act.
The NPR titled ‘‘Regulatory Capital
Rules: Standardized Approach for Riskweighted Assets; Market Discipline and
Disclosure Requirements’’ 6 (the
Standardized Approach NPR), would
revise the methodologies for calculating
risk-weighted assets in the agencies’ and
the FDIC’s general risk-based capital
rules 7 (the general risk-based capital
rules), incorporating aspects of the Basel
II standardized approach,8 and establish
alternative standards of
creditworthiness in place of credit
ratings, consistent with section 939A of
the Dodd-Frank Act.9 The proposed
minimum capital requirements in
section 10(a) of the Basel III NPR, as
determined using the standardized
capital ratio calculations in section
10(b), would establish minimum capital
requirements that would be the
‘‘generally applicable’’ capital
requirements for purpose of section 171
of the Dodd-Frank Act.10
The NPR titled ‘‘Regulatory Capital
Rules: Advanced Approaches RiskBased Capital Rule; Market Risk Capital
5 77
FR 52792 (August 30, 2012).
FR 52888 (August 30, 2012).
7 The agencies’ and the FDIC’s general risk-based
capital rules are at 12 CFR part 3, appendix A
(national banks) and 12 CFR part 167 (Federal
savings associations) (OCC); 12 CFR parts 208 and
225, appendix A (Board); and 12 CFR part 325,
appendix A, and 12 CFR part 390, subpart Z (FDIC).
The general risk-based capital rules are
supplemented by the market risk rule.
8 See BCBS, ‘‘International Convergence of
Capital Measurement and Capital Standards: A
Revised Framework,’’ (June 2006), available at
https://www.bis.org/publ/bcbs128.htm (Basel II).
9 See section 939A of the Dodd-Frank Act (15
U.S.C. 78o–7 note).
10 See 77 FR 52856 (August 30, 2012).
6 77
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Rule’’ 11 (the Advanced Approaches
NPR) included proposed changes to the
agencies’ and the FDIC’s current
advanced approaches risk-based capital
rules (the advanced approaches rule) 12
to incorporate applicable provisions of
Basel III and the ‘‘Enhancements to the
Basel II framework’’ (2009
Enhancements) published in July
2009 13 and subsequent consultative
papers, to remove references to credit
ratings, to apply the market risk rule to
savings associations and SLHCs, and to
apply the advanced approaches rule to
SLHCs meeting the scope of application
of those rules. Taken together, the three
proposals also would have restructured
the agencies’ and the FDIC’s regulatory
capital rules (the general risk-based
capital rules, leverage rules,14 market
risk rule, and advanced approaches
rule) into a harmonized, codified
regulatory capital framework.
The agencies are adopting the Basel III
NPR, Standardized Approach NPR, and
Advanced Approaches NPR in this final
rule, with certain changes to the
proposals, as described further below.
(The Board approved this final rule on
July 2, 2013, and the OCC approved this
final rule on July 9, 2013. The FDIC
approved a similar regulation as an
interim final rule on July 9, 2013.) This
final rule applies to all banking
organizations currently subject to
minimum capital requirements,
including national banks, state member
banks, state nonmember banks, state
and Federal savings associations, toptier bank holding companies (BHCs) that
are domiciled in the United States and
are not subject to the Board’s Small
Bank Holding Company Policy
Statement, and top-tier SLHCs that are
domiciled in the United States and that
do not engage substantially in insurance
underwriting or commercial activities,
as discussed further below (together,
banking organizations). Generally, BHCs
with total consolidated assets of less
than $500 million (small BHCs) remain
11 77
FR 52978 (August 30, 2012).
agencies’ and the FDIC’s advanced
approaches rules are at 12 CFR part 3, appendix C
(national banks) and 12 CFR part 167, appendix C
(Federal savings associations) (OCC); 12 CFR part
208, appendix F, and 12 CFR part 225, appendix
G (Board); 12 CFR part 325, appendix D, and 12
CFR part 390, subpart Z, appendix A (FDIC). The
advanced approaches rules are supplemented by
the market risk rule.
13 See ‘‘Enhancements to the Basel II framework’’
(July 2009), available at https://www.bis.org/publ/
bcbs157.htm.
14 The agencies’ and the FDIC’s tier 1 leverage
rules are at 12 CFR 3.6(b) and 3.6(c) (national
banks) and 167.6 (Federal savings associations)
(OCC); 12 CFR part 208, appendix B, and 12 CFR
part 225, appendix D (Board); and 12 CFR 325.3,
and 390.467 (FDIC).
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subject to the Board’s Small Bank
Holding Company Policy Statement.15
Certain aspects of this final rule apply
only to banking organizations subject to
the advanced approaches rule
(advanced approaches banking
organizations) or to banking
organizations with significant trading
activities, as further described below.
Likewise, the enhanced disclosure
requirements in the final rule apply
only to banking organizations with $50
billion or more in total consolidated
assets. Consistent with section 171 of
the Dodd-Frank Act, a BHC subsidiary
of a foreign banking organization that is
currently relying on the Board’s
Supervision and Regulation Letter (SR)
01–1 is not required to comply with the
requirements of the final rule until July
21, 2015. Thereafter, all top-tier U.S.domiciled BHC subsidiaries of foreign
banking organizations will be required
to comply with the final rule, subject to
applicable transition arrangements set
forth in subpart G of the rule.16 The
final rule reorganizes the agencies’
regulatory capital rules into a
harmonized, codified regulatory capital
framework.
As under the proposal, the minimum
capital requirements in section 10(a) of
the final rule, as determined using the
standardized capital ratio calculations
in section 10(b), which apply to all
banking organizations, establish the
‘‘generally applicable’’ capital
requirements under section 171 of the
Dodd-Frank Act.17
Under the final rule, as under the
proposal, in order to determine its
minimum risk-based capital
requirements, an advanced approaches
banking organization that has completed
the parallel run process and that has
received notification from its primary
Federal supervisor pursuant to section
121(d) of subpart E must determine its
minimum risk-based capital
requirements by calculating the three
risk-based capital ratios using total riskweighted assets under the standardized
15 See 12 CFR part 225, appendix C (Small Bank
Holding Company Policy Statement).
16 See section 171(b)(4)(E) of the Dodd-Frank Act
(12 U.S.C. 5371(b)(4)(E)); see also SR 01–1 (January
5, 2001), available at https://www.federalreserve.gov/
boarddocs/srletters/2001/sr0101.htm. In addition,
the Board has proposed to apply specific enhanced
capital standards to certain U.S. subsidiaries of
foreign banking organizations beginning on July 1,
2015, under the proposed notice of rulemaking
issued by the Board to implement sections 165 and
166 of the Dodd-Frank Act. See 77 FR 76628, 76640,
76681–82 (December 28, 2012).
17 See note 12, supra. Risk-weighted assets
calculated under the market risk framework in
subpart F of the final rule are included in
calculations of risk-weighted assets both under the
standardized approach and the advanced
approaches.
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approach and, separately, total riskweighted assets under the advanced
approaches.18 The lower ratio for each
risk-based capital requirement is the
ratio the banking organization must use
to determine its compliance with the
minimum capital requirement.19 These
enhanced prudential standards help
ensure that advanced approaches
banking organizations, which are among
the largest and most complex banking
organizations, have capital adequate to
address their more complex operations
and risks.
II. Summary of the Three Notices of
Proposed Rulemaking
A. The Basel III Notice of Proposed
Rulemaking
As discussed in the proposals, the
recent financial crisis demonstrated that
the amount of high-quality capital held
by banking organizations was
insufficient to absorb the losses
generated over that period. In addition,
some non-common stock capital
instruments included in tier 1 capital
did not absorb losses to the extent
previously expected. A lack of clear and
easily understood disclosures regarding
the characteristics of regulatory capital
instruments, as well as inconsistencies
in the definition of capital across
jurisdictions, contributed to difficulties
in evaluating a banking organization’s
capital strength. Accordingly, the BCBS
assessed the international capital
framework and, in 2010, published
Basel III, a comprehensive reform
package designed to improve the quality
and quantity of regulatory capital and
build additional capacity into the
banking system to absorb losses in times
of market and economic stress. On
August 30, 2012, the agencies and the
FDIC published the NPRs in the Federal
Register to revise regulatory capital
requirements, as discussed above. As
proposed, the Basel III NPR generally
would have applied to all U.S. banking
organizations.
Consistent with Basel III, the Basel III
NPR would have required banking
organizations to comply with the
following minimum capital ratios: (i) A
new requirement for a ratio of common
equity tier 1 capital to risk-weighted
assets (common equity tier 1 capital
ratio) of 4.5 percent; (ii) a ratio of tier
1 capital to risk-weighted assets (tier 1
capital ratio) of 6 percent, increased
from 4 percent; (iii) a ratio of total
capital to risk-weighted assets (total
capital ratio) of 8 percent; (iv) a ratio of
18 The banking organization must also use its
advanced-approaches-adjusted total to determine its
total risk-based capital ratio.
19 See section 10(c) of the final rule.
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tier 1 capital to average total
consolidated assets (leverage ratio) of 4
percent; and (v) for advanced
approaches banking organizations only,
an additional requirement that the ratio
of tier 1 capital to total leverage
exposure (supplementary leverage ratio)
be at least 3 percent.
The Basel III NPR also proposed
implementation of a capital
conservation buffer equal to 2.5 percent
of risk-weighted assets above the
minimum risk-based capital ratio
requirements, which could be expanded
by a countercyclical capital buffer for
advanced approaches banking
organizations under certain
circumstances. If a banking organization
failed to hold capital above the
minimum capital ratios and proposed
capital conservation buffer (as
potentially expanded by the
countercyclical capital buffer), it would
be subject to certain restrictions on
capital distributions and discretionary
bonus payments. The proposed
countercyclical capital buffer was
designed to take into account the macrofinancial environment in which large,
internationally active banking
organizations function. The
countercyclical capital buffer could be
implemented if the agencies and the
FDIC determined that credit growth in
the economy became excessive. As
proposed, the countercyclical capital
buffer would initially be set at zero, and
could expand to as much as 2.5 percent
of risk-weighted assets.
The Basel III NPR proposed to apply
a 4 percent minimum leverage ratio
requirement to all banking organizations
(computed using the new definition of
capital), and to eliminate the exceptions
for banking organizations with strong
supervisory ratings or subject to the
market risk rule. The Basel III NPR also
proposed to require advanced
approaches banking organizations to
satisfy a minimum supplementary
leverage ratio requirement of 3 percent,
measured in a manner consistent with
the international leverage ratio set forth
in Basel III. Unlike the agencies’ current
leverage ratio requirement, the proposed
supplementary leverage ratio
incorporates certain off-balance sheet
exposures in the denominator.
To strengthen the quality of capital,
the Basel III NPR proposed more
conservative eligibility criteria for
regulatory capital instruments. For
example, the Basel III NPR proposed
that trust preferred securities (TruPS)
and cumulative perpetual preferred
securities, which were tier-1-eligible
instruments (subject to limits) at the
BHC level, would no longer be
includable in tier 1 capital under the
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proposal and would be gradually
phased out from tier 1 capital. The
proposal also eliminated the existing
limitations on the amount of tier 2
capital that could be recognized in total
capital, as well as the limitations on the
amount of certain capital instruments
(for example, term subordinated debt)
that could be included in tier 2 capital.
In addition, the proposal would have
required banking organizations to
include in common equity tier 1 capital
accumulated other comprehensive
income (AOCI) (with the exception of
gains and losses on cash-flow hedges
related to items that are not fair-valued
on the balance sheet), and also would
have established new limits on the
amount of minority interest a banking
organization could include in regulatory
capital. The proposal also would have
established more stringent requirements
for several deductions from and
adjustments to regulatory capital,
including with respect to deferred tax
assets (DTAs), investments in a banking
organization’s own capital instruments
and the capital instruments of other
financial institutions, and mortgage
servicing assets (MSAs). The proposed
revisions would have been incorporated
into the regulatory capital ratios in the
prompt corrective action (PCA)
framework for depository institutions.
B. The Standardized Approach Notice
of Proposed Rulemaking
The Standardized Approach NPR
proposed changes to the agencies’ and
the FDIC’s general risk-based capital
rules for determining risk-weighted
assets (that is, the calculation of the
denominator of a banking organization’s
risk-based capital ratios). The proposed
changes were intended to revise and
harmonize the agencies’ and the FDIC’s
rules for calculating risk-weighted
assets, enhance risk sensitivity, and
address weaknesses in the regulatory
capital framework identified over recent
years, including by strengthening the
risk sensitivity of the regulatory capital
treatment for, among other items, credit
derivatives, central counterparties
(CCPs), high-volatility commercial real
estate, and collateral and guarantees.
In the Standardized Approach NPR,
the agencies and the FDIC also proposed
alternatives to credit ratings for
calculating risk-weighted assets for
certain assets, consistent with section
939A of the Dodd-Frank Act. These
alternatives included methodologies for
determining risk-weighted assets for
exposures to sovereigns, foreign banks,
and public sector entities, securitization
exposures, and counterparty credit risk.
The Standardized Approach NPR also
proposed to include a framework for
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risk weighting residential mortgages
based on underwriting and product
features, as well as loan-to-value (LTV)
ratios, and disclosure requirements for
top-tier banking organizations
domiciled in the United States with $50
billion or more in total assets, including
disclosures related to regulatory capital
instruments.
C. The Advanced Approaches Notice of
Proposed Rulemaking
The Advanced Approaches NPR
proposed revisions to the advanced
approaches rule to incorporate certain
aspects of Basel III, the 2009
Enhancements, and subsequent
consultative papers. The proposal also
would have implemented relevant
provisions of the Dodd-Frank Act,
including section 939A (regarding the
use of credit ratings in agency
regulations),20 and incorporated certain
technical amendments to the existing
requirements. In addition, the Advanced
Approaches NPR proposed to codify the
market risk rule in a manner similar to
the codification of the other regulatory
capital rules under the proposals.
Consistent with Basel III and the 2009
Enhancements, under the Advanced
Approaches NPR, the agencies and the
FDIC proposed further steps to
strengthen capital requirements for
internationally active banking
organizations. This NPR would have
required advanced approaches banking
organizations to hold more appropriate
levels of capital for counterparty credit
risk, credit valuation adjustments
(CVA), and wrong-way risk; would have
strengthened the risk-based capital
requirements for certain securitization
exposures by requiring advanced
approaches banking organizations to
conduct more rigorous credit analysis of
securitization exposures; and would
have enhanced the disclosure
requirements related to those exposures.
The Board proposed to apply the
advanced approaches rule to SLHCs,
and the agencies and the FDIC proposed
to apply the market risk rule to SLHCs
and to state and Federal savings
associations.
20 See section 939A of Dodd-Frank Act (15 U.S.C.
78o-7 note).
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III. Summary of General Comments on
the Basel III Notice of Proposed
Rulemaking and on the Standardized
Approach Notice of Proposed
Rulemaking; Overview of the Final
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A. General Comments on the Basel III
Notice of Proposed Rulemaking and on
the Standardized Approach Notice of
Proposed Rulemaking
Each agency received over 2,500
public comments on the proposals from
banking organizations, trade
associations, supervisory authorities,
consumer advocacy groups, public
officials (including members of the U.S.
Congress), private individuals, and
other interested parties. Overall, while
most commenters supported more
robust capital standards and the
agencies’ and the FDIC’s efforts to
improve the resilience of the banking
system, many commenters expressed
concerns about the potential costs and
burdens of various aspects of the
proposals, particularly for smaller
banking organizations. A substantial
number of commenters also requested
withdrawal of, or significant revisions
to, the proposals. A few commenters
argued that new capital rules were not
necessary at this time. Some
commenters requested that the agencies
and the FDIC perform additional studies
of the economic impact of part or all of
the proposed rules. Many commenters
asked for additional time to transition to
the new requirements. A more detailed
discussion of the comments provided on
particular aspects of the proposals is
provided in the remainder of this
preamble.
1. Applicability and Scope
The agencies and the FDIC received a
significant number of comments
regarding the proposed scope and
applicability of the Basel III NPR and
the Standardized Approach NPR. The
majority of comments submitted by or
on behalf of community banking
organizations requested an exemption
from the proposals. These commenters
suggested basing such an exemption on
a banking organization’s asset size—for
example, total assets of less than $500
million, $1 billion, $10 billion, $15
billion, or $50 billion—or on its risk
profile or business model. Under the
latter approach, the commenters
suggested providing an exemption for
banking organizations with balance
sheets that rely less on leverage, shortterm funding, or complex derivative
transactions.
In support of an exemption from the
proposed rule for community banking
organizations, a number of commenters
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argued that the proposed revisions to
the definition of capital would be overly
conservative and would prohibit some
of the instruments relied on by
community banking organizations from
satisfying regulatory capital
requirements. Many of these
commenters stated that, in general,
community banking organizations have
less access to the capital markets
relative to larger banking organizations
and could increase capital only by
accumulating retained earnings. Owing
to slow economic growth and relatively
low earnings among community
banking organizations, the commenters
asserted that implementation of the
proposal would be detrimental to their
ability to serve local communities while
providing reasonable returns to
shareholders. Other commenters
requested exemptions from particular
sections of the proposed rules, such as
maintaining capital against transactions
with particular counterparties, or based
on transaction types that they
considered lower-risk, such as
derivative transactions hedging interest
rate risk.
The commenters also argued that
application of the Basel III NPR and
Standardized Approach NPR to
community banking organizations
would be unnecessary and
inappropriate for the business model
and risk profile of such organizations.
These commenters asserted that Basel III
was designed for large, internationallyactive banking organizations in response
to a financial crisis attributable
primarily to those institutions.
Accordingly, the commenters were of
the view that community banking
organizations require a different capital
framework with less stringent capital
requirements, or should be allowed to
continue to use the general risk-based
capital rules. In addition, many
commenters, in particular minority
depository institutions (MDIs), mutual
banking organizations, and community
development financial institutions
(CDFIs), expressed concern regarding
their ability to raise capital to meet the
increased minimum requirements in the
current environment and upon
implementation of the proposed
definition of capital. One commenter
asked for an exemption from all or part
of the proposed rules for CDFIs,
indicating that the proposal would
significantly reduce the availability of
capital for low- and moderate-income
communities. Another commenter
stated that the U.S. Congress has a
policy of encouraging the creation of
MDIs and expressed concern that the
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proposed rules contradicted this
purpose.
In contrast, however, a few
commenters supported the proposed
application of the Basel III NPR to all
banking organizations. For example, one
commenter stated that increasing the
quality and quantity of capital at all
banking organizations would create a
more resilient financial system and
discourage inappropriate risk-taking by
forcing banking organizations to put
more of their own ‘‘skin in the game.’’
This commenter also asserted that the
proposed scope of the Basel III NPR
would reduce the probability and
impact of future financial crises and
support the objectives of sustained
growth and high employment. Another
commenter favored application of the
Basel III NPR to all banking
organizations to ensure a level playing
field among banking organizations
within the same competitive market.
Comments submitted by or on behalf
of banking organizations that are
engaged primarily in insurance
activities also requested an exemption
from the Basel III NPR and the
Standardized Approach NPR to
recognize differences in their business
model compared with those of more
traditional banking organizations.
According to the commenters, the
activities of these organizations are
fundamentally different from traditional
banking organizations and have a
unique risk profile. One commenter
expressed concern that the Basel III NPR
focuses primarily on assets in the
denominator of the risk-based capital
ratio as the primary basis for
determining capital requirements, in
contrast to capital requirements for
insurance companies, which are based
on the relationship between a
company’s assets and liabilities.
Similarly, other commenters expressed
concern that bank-centric rules would
conflict with the capital requirements of
state insurance regulators and provide
regulatory incentives for unsound assetliability mismatches. Several
commenters argued that the U.S.
Congress intended that banking
organizations primarily engaged in
insurance activities should be covered
by different capital regulations that
accounted for the characteristics of
insurance activities. These commenters,
therefore, encouraged the agencies and
the FDIC to recognize capital
requirements adopted by state insurance
regulators. Further, commenters
asserted that the agencies and the FDIC
did not appropriately consider
regulatory capital requirements for
insurance-based banking organizations
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whose banking operations are a small
part of their overall operations.
Some SLHC commenters that are
substantially engaged in commercial
activities also asserted that the
proposals would be inappropriate in
scope as proposed and asked that
capital rules not be applied to them
until an intermediate holding company
regime could be established. They also
requested that any capital regime
applicable to them be tailored to take
into consideration their commercial
operations and that they be granted
longer transition periods.
As noted above, small BHCs are
exempt from the final rule (consistent
with the proposals and section 171 of
the Dodd-Frank Act) and continue to be
subject to the Board’s Small Bank
Holding Company Policy Statement.
Comments submitted on behalf of
SLHCs with assets less than $500
million requested an analogous
exemption to that for small BHCs. These
commenters argued that section 171 of
the Dodd-Frank Act does not prohibit
such an exemption for small SLHCs.
2. Aggregate Impact
A majority of the commenters
expressed concern regarding the
potential aggregate impact of the
proposals, together with other
provisions of the Dodd-Frank Act. Some
of these commenters urged the agencies
and the FDIC to withdraw the proposals
and to conduct a quantitative impact
study (QIS) to assess the potential
aggregate impact of the proposals on
banking organizations and the overall
U.S. economy. Many commenters
argued that the proposals would have
significant negative consequences for
the financial services industry.
According to the commenters, by
requiring banking organizations to hold
more capital and increase risk weighting
on some of their assets, as well as to
meet higher risk-based and leverage
capital measures for certain PCA
categories, the proposals would
negatively affect the banking sector.
Commenters cited, among other
potential consequences of the proposals:
restricted job growth; reduced lending
or higher-cost lending, including to
small businesses and low-income or
minority communities; limited
availability of certain types of financial
products; reduced investor demand for
banking organizations’ equity; higher
compliance costs; increased mergers
and consolidation activity, specifically
in rural markets, because banking
organizations would need to spread
compliance costs among a larger
customer base; and diminished access to
the capital markets resulting from
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reduced profit and from dividend
restrictions associated with the capital
buffers. The commenters also asserted
that the recovery of the U.S. economy
would be impaired by the proposals as
a result of reduced lending by banking
organizations that the commenters
believed would be attributable to the
higher costs of regulatory compliance.
In particular, the commenters expressed
concern that a contraction in smallbusiness lending would adversely affect
job growth and employment.
3. Competitive Concerns
Many commenters raised concerns
that implementation of the proposals
would create an unlevel playing field
between banking organizations and
other financial services providers. For
example, a number of commenters
expressed concern that credit unions
would be able to gain market share from
banking organizations by offering
similar products at substantially lower
costs because of differences in taxation
combined with potential costs from the
proposals. The commenters also argued
that other financial service providers,
such as foreign banks with significant
U.S. operations, members of the Federal
Farm Credit System, and entities in the
shadow banking industry, would not be
subject to the proposed rule and,
therefore, would have a competitive
advantage over banking organizations.
These commenters also asserted that the
proposals could cause more consumers
to choose lower-cost financial products
from the unregulated, nonbank financial
sector.
4. Costs
Commenters representing all types of
banking organizations expressed
concern that the complexity and
implementation cost of the proposals
would exceed their expected benefits.
According to these commenters,
implementation of the proposals would
require software upgrades for new
internal reporting systems, increased
employee training, and the hiring of
additional employees for compliance
purposes. Some commenters urged the
agencies and the FDIC to recognize that
compliance costs have increased
significantly over recent years due to
other regulatory changes and to take
these costs into consideration. As an
alternative, some commenters
encouraged the agencies and the FDIC to
consider a simple increase in the
minimum regulatory capital
requirements, suggesting that such an
approach would provide increased
protection to the Deposit Insurance
Fund and increase safety and soundness
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without adding complexity to the
regulatory capital framework.
B. Comments on Particular Aspects of
the Basel III Notice of Proposed
Rulemaking and on the Standardized
Approach Notice of Proposed
Rulemaking
In addition to the general comments
described above, the agencies and the
FDIC received a significant number of
comments on four particular elements of
the proposals: the requirement to
include most elements of AOCI in
regulatory capital; the new framework
for risk weighting residential mortgages;
the requirement to phase out TruPS
from tier 1 capital for all banking
organizations; and the application of the
rule to BHCs and SLHCs (collectively,
depository institution holding
companies) with substantial insurance
and commercial activities.
1. Accumulated Other Comprehensive
Income
AOCI generally includes accumulated
unrealized gains and losses on certain
assets and liabilities that have not been
included in net income, yet are
included in equity under U.S. generally
accepted accounting principles (GAAP)
(for example, unrealized gains and
losses on securities designated as
available-for-sale (AFS)). Under the
agencies’ and the FDIC’s general riskbased capital rules, most components of
AOCI are not reflected in a banking
organization’s regulatory capital. In the
proposed rule, consistent with Basel III,
the agencies and the FDIC proposed to
require banking organizations to include
the majority of AOCI components in
common equity tier 1 capital.
The agencies and the FDIC received a
significant number of comments on the
proposal to require banking
organizations to recognize AOCI in
common equity tier 1 capital. Generally,
the commenters asserted that the
proposal would introduce significant
volatility in banking organizations’
capital ratios due in large part to
fluctuations in benchmark interest rates,
and would result in many banking
organizations moving AFS securities
into a held-to-maturity (HTM) portfolio
or holding additional regulatory capital
solely to mitigate the volatility resulting
from temporary unrealized gains and
losses in the AFS securities portfolio.
The commenters also asserted that the
proposed rules would likely impair
lending and negatively affect banking
organizations’ ability to manage
liquidity and interest rate risk and to
maintain compliance with legal lending
limits. Commenters representing
community banking organizations in
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particular asserted that they lack the
sophistication of larger banking
organizations to use certain riskmanagement techniques for hedging
interest rate risk, such as the use of
derivative instruments.
2. Residential Mortgages
The Standardized Approach NPR
would have required banking
organizations to place residential
mortgage exposures into one of two
categories to determine the applicable
risk weight. Category 1 residential
mortgage exposures were defined to
include mortgage products with
underwriting and product features that
have demonstrated a lower risk of
default, such as consideration and
documentation of a borrower’s ability to
repay, and generally excluded mortgage
products that included terms or other
characteristics that the agencies and the
FDIC have found to be indicative of
higher credit risk, such as deferral of
repayment of principal. Residential
mortgage exposures with higher risk
characteristics were defined as category
2 residential mortgage exposures. The
agencies and the FDIC proposed to
apply relatively lower risk weights to
category 1 residential mortgage
exposures, and higher risk weights to
category 2 residential mortgage
exposures. The proposal provided that
the risk weight assigned to a residential
mortgage exposure also depended on its
LTV ratio.
The agencies and the FDIC received a
significant number of comments
objecting to the proposed treatment for
one-to-four family residential mortgages
and requesting retention of the mortgage
treatment in the agencies’ and the
FDIC’s general risk-based capital rules.
Commenters generally expressed
concern that the proposed treatment
would inhibit lending to creditworthy
borrowers and could jeopardize the
recovery of a still-fragile housing
market. Commenters also criticized the
distinction between category 1 and
category 2 mortgages, asserting that the
characteristics proposed for each
category did not appropriately
distinguish between lower- and higherrisk products and would adversely
impact certain loan products that
performed relatively well even during
the recent crisis. Commenters also
highlighted concerns regarding
regulatory burden and the uncertainty of
other regulatory initiatives involving
residential mortgages. In particular,
these commenters expressed
considerable concern regarding the
potential cumulative impact of the
proposed new mortgage requirements
combined with the Dodd-Frank Act’s
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requirements relating to the definitions
of qualified mortgage and qualified
residential mortgage 21 and asserted that
when considered together with the
proposed mortgage treatment, the
combined effect could have an adverse
impact on the mortgage industry.
3. Trust Preferred Securities for Smaller
Banking Organizations
The proposed rules would have
required all banking organizations to
phase-out TruPS from tier 1 capital
under either a 3- or 10-year transition
period based on the organization’s total
consolidated assets. The proposal would
have required banking organizations
with more than $15 billion in total
consolidated assets (as of December 31,
2009) to phase-out of tier 1 capital any
non-qualifying capital instruments
(such as TruPS and cumulative
preferred shares) issued before May 19,
2010. The exclusion of non-qualifying
capital instruments would have taken
place incrementally over a three-year
period beginning on January 1, 2013.
Section 171 provides an exception that
permits banking organizations with total
consolidated assets of less than $15
billion as of December 31, 2009, and
banking organizations that were mutual
holding companies as of May 19, 2010
(2010 MHCs), to include in tier 1 capital
all TruPS (and other instruments that
could no longer be included in tier 1
capital pursuant to the requirements of
section 171) that were issued prior to
May 19, 2010.22 However, consistent
with Basel III and the general policy
purpose of the proposed revisions to
regulatory capital, the agencies and the
FDIC proposed to require banking
organizations with total consolidated
assets less than $15 billion as of
December 31, 2009 and 2010 MHCs to
phase out their non-qualifying capital
instruments from regulatory capital over
ten years.23
21 See, e.g., the definition of ‘‘qualified mortgage’’
in section 1412 of the Dodd-Frank Act (15 U.S.C.
129C) and ‘‘qualified residential mortgage’’ in
section 941(e)(4) of the Dodd-Frank Act (15 U.S.C.
78o-11(e)(4)).
22 Specifically, section 171 provides that
deductions of instruments ‘‘that would be required’’
under the section are not required for depository
institution holding companies with total
consolidated assets of less than $15 billion as of
December 31, 2009 and 2010 MHCs. See 12 U.S.C.
5371(b)(4)(C).
23 See 12 U.S.C. 5371(b)(5)(A). While section 171
of the Dodd-Frank Act requires the agencies to
establish minimum risk-based and leverage capital
requirements subject to certain limitations, the
agencies and the FDIC retain their general authority
to establish capital requirements under other laws
and regulations, including under the National Bank
Act, 12 U.S.C. 1, et seq., Federal Reserve Act,
Federal Deposit Insurance Act, Bank Holding
Company Act, International Lending Supervision
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Many commenters representing
community banking organizations
criticized the proposal’s phase-out
schedule for TruPS and encouraged the
agencies and the FDIC to grandfather
TruPS in tier 1 capital to the extent
permitted by section 171 of the DoddFrank Act. Commenters asserted that
this was the intent of the U.S. Congress,
including this provision in the statute.
These commenters also asserted that
this aspect of the proposal would
unduly burden community banking
organizations that have limited ability to
raise capital, potentially impairing the
lending capacity of these banking
organizations.
4. Insurance Activities
The agencies and the FDIC received
numerous comments from SLHCs, trade
associations, insurance companies, and
members of the U.S. Congress on the
proposed capital requirements for
SLHCs, in particular those with
significant insurance activities. As
noted above, commenters raised
concerns that the proposed
requirements would apply what are
perceived as bank-centric consolidated
capital requirements to these entities.
Commenters suggested incorporating
insurance risk-based capital
requirements established by the state
insurance regulators into the Board’s
consolidated risk-based capital
requirements for the holding company,
or including certain insurance riskbased metrics that, in the commenters’
view, would measure the risk of
insurance activities more accurately. A
few commenters asked the Board to
conduct an additional cost-benefit
analysis prior to implementing the
proposed capital requirements for this
subset of SLHCs. In addition, several
commenters expressed concern with the
burden associated with the proposed
requirement to prepare financial
statements according to GAAP, because
a few SLHCs with substantial insurance
operations only prepare financial
statements according to Statutory
Accounting Principles (SAP). These
commenters noted that the Board has
accepted non-GAAP financial
statements from foreign entities in the
past for certain non-consolidated
reporting requirements related to the
foreign subsidiaries of U.S. banking
organizations.24
Some commenters stated that the
proposal presents serious issues in light
Act, 12 U.S.C. 3901, et seq., and Home Owners
Loan Act, 12 U.S.C. 1461, et seq.
24 See form FR 2314.
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of the McCarran-Ferguson Act.25 These
commenters stated that section 171 of
the Dodd-Frank Act does not
specifically refer to the business of
insurance. Further, the commenters
asserted that the proposal disregards the
state-based regulatory capital and
reserving regimes applicable to
insurance companies and thus would
impair the solvency laws enacted by the
states for the purpose of regulating
insurance. The commenters also said
that the proposal would alter the riskmanagement practices and other aspects
of the insurance business conducted in
accordance with the state laws, in
contravention of the McCarran-Ferguson
Act. Some commenters also cited
section 502 of the Dodd-Frank Act,
asserting that it continues the primacy
of state regulation of insurance
companies.26
C. Overview of the Final Rule
The final rule will replace the
agencies’ general risk-based capital
rules, advanced approaches rule, market
risk rule, and leverage rules in
accordance with the transition
provisions described below. After
considering the comments received, the
agencies have made substantial
modifications in the final rule to
address specific concerns raised by
commenters regarding the cost,
complexity, and burden of the
proposals.
During the recent financial crisis, lack
of confidence in the banking sector
increased banking organizations’ cost of
funding, impaired banking
organizations’ access to short-term
funding, depressed values of banking
organizations’ equities, and required
many banking organizations to seek
government assistance. Concerns about
banking organizations arose not only
because market participants expected
steep losses on banking organizations’
assets, but also because of substantial
uncertainty surrounding estimated loss
rates, and thus future earnings. Further,
heightened systemic risks, falling asset
values, and reduced credit availability
had an adverse impact on business and
consumer confidence, significantly
affecting the overall economy. The final
rule addresses these weaknesses by
helping to ensure a banking and
financial system that will be better able
to absorb losses and continue to lend in
25 The McCarran-Ferguson Act provides that
‘‘[N]o act of Congress shall be construed to
invalidate, impair, or supersede any law enacted by
any State for the purpose of regulating the business
of insurance . . . unless such Act specifically
relates to the business of insurance.’’ 15 U.S.C.
1012.
26 31 U.S.C. 313(f).
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future periods of economic stress. This
important benefit in the form of a safer,
more resilient, and more stable banking
system is expected to substantially
outweigh any short-term costs that
might result from the final rule.
In this context, the agencies are
adopting most aspects of the proposals,
including the minimum risk-based
capital requirements, the capital
conservation and countercyclical capital
buffers, and many of the proposed risk
weights. The agencies have also decided
to apply most aspects of the Basel III
NPR and Standardized Approach NPR
to all banking organizations, with some
significant changes. Implementing the
final rule in a consistent fashion across
the banking system will improve the
quality and increase the level of
regulatory capital, leading to a more
stable and resilient system for banking
organizations of all sizes and risk
profiles. The improved resilience will
enhance their ability to continue
functioning as financial intermediaries,
including during periods of financial
stress and reduce risk to the deposit
insurance fund and to the financial
system. The agencies believe that,
together, the revisions to the proposals
meaningfully address the commenters’
concerns regarding the potential
implementation burden of the
proposals.
The agencies have considered the
concerns raised by commenters and
believe that it is important to take into
account and address regulatory costs
(and their potential effect on banking
organizations’ role as financial
intermediaries in the economy) when
the agencies establish or revise
regulatory requirements. In developing
regulatory capital requirements, these
concerns are considered in the context
of the agencies’ broad goals—to enhance
the safety and soundness of banking
organizations and promote financial
stability through robust capital
standards for the entire banking system.
The agencies participated in the
development of a number of studies to
assess the potential impact of the
revised capital requirements, including
participating in the BCBS’s
Macroeconomic Assessment Group as
well as its QIS, the results of which
were made publicly available by the
BCBS upon their completion.27 The
BCBS analysis suggested that stronger
capital requirements help reduce the
27 See ‘‘Assessing the macroeconomic impact of
the transition to stronger capital and liquidity
requirements’’ (MAG Analysis), Attachment E, also
available at: https://www.bis.orpublIothp12.pdf. See
also ‘‘Results of the comprehensive quantitative
impact study,’’ Attachment F, also available at:
https://www.bis.org/publ/bcbs186.pdf.
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likelihood of banking crises while
yielding positive net economic
benefits.28 To evaluate the potential
reduction in economic output resulting
from the new framework, the analysis
assumed that banking organizations
replaced debt with higher-cost equity to
the extent needed to comply with the
new requirements, that there was no
reduction in the cost of equity despite
the reduction in the riskiness of banking
organizations’ funding mix, and that the
increase in funding cost was entirely
passed on to borrowers. Given these
assumptions, the analysis concluded
there would be a slight increase in the
cost of borrowing and a slight decrease
in the growth of gross domestic product.
The analysis concluded that this cost
would be more than offset by the benefit
to gross domestic product resulting from
a reduced likelihood of prolonged
economic downturns associated with a
banking system whose lending capacity
is highly vulnerable to economic
shocks.
The agencies’ analysis also indicates
that the overwhelming majority of
banking organizations already have
sufficient capital to comply with the
final rule. In particular, the agencies
estimate that over 95 percent of all
insured depository institutions would
be in compliance with the minimums
and buffers established under the final
rule if it were fully effective
immediately. The final rule will help to
ensure that these banking organizations
maintain their capacity to absorb losses
in the future. Some banking
organizations may need to take
advantage of the transition period in the
final rule to accumulate retained
earnings, raise additional external
regulatory capital, or both. As noted
above, however, the overwhelming
majority of banking organizations have
sufficient capital to comply with the
final rule, and the agencies believe that
the resulting improvements to the
stability and resilience of the banking
system outweigh any costs associated
with its implementation.
The final rule includes some
significant revisions from the proposals
in response to commenters’ concerns,
particularly with respect to the
treatment of AOCI; residential
mortgages; tier 1 non-qualifying capital
instruments such as TruPS issued by
smaller depository institution holding
companies; the applicability of the rule
to SLHCs with substantial insurance or
commercial activities; and the
28 See ‘‘An assessment of the long-term economic
impact of stronger capital and liquidity
requirements,’’ Executive Summary, pg. 1,
Attachment G.
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implementation timeframes. The
timeframes for compliance are described
in the next section and more detailed
discussions of modifications to the
proposals are provided in the remainder
of the preamble.
Consistent with the proposed rules,
the final rule requires all banking
organizations to recognize in regulatory
capital all components of AOCI,
excluding accumulated net gains and
losses on cash-flow hedges that relate to
the hedging of items that are not
recognized at fair value on the balance
sheet. However, while the agencies
believe that the proposed AOCI
treatment results in a regulatory capital
measure that better reflects banking
organizations’ actual loss absorption
capacity at a specific point in time, the
agencies recognize that for many
banking organizations, the volatility in
regulatory capital that could result from
the proposals could lead to significant
difficulties in capital planning and
asset-liability management. The
agencies also recognize that the tools
used by larger, more complex banking
organizations for managing interest rate
risk are not necessarily readily available
for all banking organizations.
Accordingly, under the final rule, and
as discussed in more detail in section
V.B of this preamble, a banking
organization that is not subject to the
advanced approaches rule may make a
one-time election not to include most
elements of AOCI in regulatory capital
under the final rule and instead
effectively use the existing treatment
under the general risk-based capital
rules that excludes most AOCI elements
from regulatory capital (AOCI opt-out
election). Such a banking organization
must make its AOCI opt-out election in
the banking organization’s Consolidated
Reports of Condition and Income (Call
Report) or FR Y–9 series report filed for
the first reporting period after the
banking organization becomes subject to
the final rule. Consistent with regulatory
capital calculations under the agencies’
general risk-based capital rules, a
banking organization that makes an
AOCI opt-out election under the final
rule must adjust common equity tier 1
capital by: (1) Subtracting any net
unrealized gains and adding any net
unrealized losses on AFS securities; (2)
subtracting any unrealized losses on
AFS preferred stock classified as an
equity security under GAAP and AFS
equity exposures; (3) subtracting any
accumulated net gains and adding any
accumulated net losses on cash-flow
hedges; (4) subtracting amounts
recorded in AOCI attributed to defined
benefit postretirement plans resulting
from the initial and subsequent
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application of the relevant GAAP
standards that pertain to such plans
(excluding, at the banking organization’s
option, the portion relating to pension
assets deducted under section 22(a)(5)
of the final rule); and (5) subtracting any
net unrealized gains and adding any net
unrealized losses on held-to-maturity
securities that are included in AOCI.
Consistent with the general risk-based
capital rules, common equity tier 1
capital includes any net unrealized
losses on AFS equity securities and any
foreign currency translation adjustment.
A banking organization that makes an
AOCI opt-out election may incorporate
up to 45 percent of any net unrealized
gains on AFS preferred stock classified
as an equity security under GAAP and
AFS equity exposures into its tier 2
capital.
A banking organization that does not
make an AOCI opt-out election on the
Call Report or applicable FR Y–9 report
filed for the first reporting period after
the banking organization becomes
subject to the final rule will be required
to recognize AOCI (excluding
accumulated net gains and losses on
cash-flow hedges that relate to the
hedging of items that are not recognized
at fair value on the balance sheet) in
regulatory capital as of the first quarter
in which it calculates its regulatory
capital requirements under the final rule
and continuing thereafter.
The agencies have decided not to
adopt the proposed treatment of
residential mortgages. The agencies
have considered the commenters’
observations about the burden of
calculating the risk weights for banking
organizations’ existing mortgage
portfolios, and have taken into account
the commenters’ concerns that the
proposal did not properly assess the use
of different mortgage products across
different types of markets in
establishing the proposed risk weights.
The agencies are also particularly
mindful of comments regarding the
potential effect of the proposal and
other mortgage-related rulemakings on
credit availability. In light of these
considerations, as well as others raised
by commenters, the agencies have
decided to retain in the final rule the
current treatment for residential
mortgage exposures under the general
risk-based capital rules.
Consistent with the general risk-based
capital rules, the final rule assigns a 50
or 100 percent risk weight to exposures
secured by one-to-four family
residential properties. Generally,
residential mortgage exposures secured
by a first lien on a one-to-four family
residential property that are prudently
underwritten and that are performing
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according to their original terms receive
a 50 percent risk weight. All other oneto four-family residential mortgage
loans, including exposures secured by a
junior lien on residential property, are
assigned a 100 percent risk weight. If a
banking organization holds the first and
junior lien(s) on a residential property
and no other party holds an intervening
lien, the banking organization must treat
the combined exposure as a single loan
secured by a first lien for purposes of
assigning a risk weight.
The agencies also considered
comments on the proposal to require
banking organizations with total
consolidated assets less than $15 billion
as of December 31, 2009, and 2010
MHCs, to phase out their non-qualifying
tier 1 capital instruments from
regulatory capital over ten years.
Although the agencies continue to
believe that TruPS do not absorb losses
sufficiently to be included in tier 1
capital as a general matter, the agencies
are also sensitive to the difficulties
community banking organizations often
face when issuing new capital
instruments and are aware of the
importance their capacity to lend can
play in local economies. Therefore, the
final rule permanently grandfathers
non-qualifying capital instruments in
the tier 1 capital of depository
institution holding companies with total
consolidated assets of less than $15
billion as of December 31, 2009, and
2010 MHCs (subject to limits). Nonqualifying capital instruments under the
final rule include TruPS and cumulative
perpetual preferred stock issued before
May 19, 2010, that BHCs included in
tier 1 capital under the limitations for
restricted capital elements in the general
risk-based capital rules.
After considering the comments
received from SLHCs substantially
engaged in commercial activities or
insurance underwriting activities, the
Board has decided to consider further
the development of appropriate capital
requirements for these companies,
taking into consideration information
provided by commenters as well as
information gained through the
supervisory process. The Board will
explore further whether and how the
proposed rule should be modified for
these companies in a manner consistent
with section 171 of the Dodd-Frank Act
and safety and soundness concerns.
Consequently, as defined in the final
rule, a covered SLHC that is subject to
the final rule (covered SLHC) is a toptier SLHC other than a top-tier SLHC
that meets the exclusion criteria set
forth in the definition. With respect to
commercial activities, a top-tier SLHC
that is a grandfathered unitary savings
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and loan holding company (as defined
in section 10(c)(9)(A) of the Home
Owners’ Loan Act (HOLA)) 29 is not a
covered SLHC if as of June 30 of the
previous calendar year, either 50
percent or more of the total consolidated
assets of the company or 50 percent of
the revenues of the company on an
enterprise-wide basis (as calculated
under GAAP) were derived from
activities that are not financial in nature
under section 4(k) of the Bank Holding
Company Act.30 This exclusion is
similar to the exemption from reporting
on the form FR Y–9C for grandfathered
unitary savings and loan holding
companies with significant commercial
activities and is designed to capture
those SLHCs substantially engaged in
commercial activities.31
The Board is excluding grandfathered
unitary savings and loan holding
companies that meet these criteria from
the capital requirements of the final rule
while it continues to contemplate a
proposal for SLHC intermediate holding
companies. Under section 626 of the
Dodd-Frank Act, the Board may require
a grandfathered unitary savings and
loan holding company to establish and
conduct all or a portion of its financial
activities in or through an intermediate
holding company and the intermediate
holding company itself becomes an
SLHC subject to Board supervision and
regulation.32 The Board anticipates that
it will release a proposal for public
comment on intermediate holding
companies in the near term that would
specify the criteria for establishing and
transferring activities to intermediate
holding companies, consistent with
section 626 of the Dodd-Frank Act, and
propose to apply the Board’s capital
requirements in this final rule to such
intermediate holding companies.
Under the final rule, top-tier SLHCs
that are substantially engaged in
insurance underwriting activities are
also excluded from the definition of
‘‘covered SLHC’’ and the requirements
of the final rule. SLHCs that are
themselves insurance underwriting
companies (as defined in the final rule)
are excluded from the definition.33 Also
excluded are SLHCs that, as of June 30
29 12
U.S.C. 1461 et seq.
U.S.C. 1843(k).
31 See 76 FR 81935 (December 29, 2011).
32 See section 626 of the Dodd-Frank Act (12
U.S.C. 1467b).
33 The final rule defines ‘‘insurance underwriting
company’’ to mean an insurance company, as
defined in section 201 of the Dodd-Frank Act (12
U.S.C. 5381), that engages in insurance
underwriting activities. This definition includes
companies engaged in insurance underwriting
activities that are subject to regulation by a State
insurance regulator and covered by a State
insurance company insolvency law.
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30 12
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of the previous calendar year, held 25
percent or more of their total
consolidated assets in insurance
underwriting subsidiaries (other than
assets associated with insurance
underwriting for credit risk). Under the
final rule, the calculation of total
consolidated assets for this purpose
must generally be in accordance with
GAAP. Many SLHCs that are
substantially engaged in insurance
underwriting activities do not calculate
total consolidated assets under GAAP.
Therefore, the Board has determined to
allow estimated calculations at this time
for the purposes of determining whether
a company is excluded from the
definition of ‘‘covered SLHC,’’ subject to
possible review and adjustment by the
Board. The Board expects to implement
a framework for SLHCs that are not
subject to the final rule by the time
covered SLHCs must comply with the
final rule in 2015. The final rule also
contains provisions applicable to
insurance underwriting activities
conducted within a BHC or covered
SLHC. These provisions are effective as
part of the final rule.
D. Timeframe for Implementation and
Compliance
In order to give covered SLHCs and
non-internationally active banking
organizations more time to comply with
the final rule and simplify their
transition to the new regime, the final
rule will require compliance from
different types of organizations at
different times. Generally, and as
described in further detail below,
banking organizations that are not
subject to the advanced approaches rule
must begin complying with the final
rule on January 1, 2015, whereas
advanced approaches banking
organizations must begin complying
with the final rule on January 1, 2014.
The agencies believe that advanced
approaches banking organizations have
the sophistication, infrastructure, and
capital markets access to implement the
final rule earlier than either banking
organizations that do not meet the asset
size or foreign exposure threshold for
application of those rules or covered
SLHCs that have not previously been
subject to consolidated capital
requirements.
A number of commenters requested
that the agencies and the FDIC clarify
the point at which a banking
organization that meets the asset size or
foreign exposure threshold for
application of the advanced approaches
rule becomes subject to subpart E of the
proposed rule, and thus all of the
provisions that apply to an advanced
approaches banking organization. In
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particular, commenters requested that
the agencies and the FDIC clarify
whether subpart E of the proposed rule
only applies to those banking
organizations that have completed the
parallel run process and that have
received notification from their primary
Federal supervisor pursuant to section
121(d) of subpart E, or whether subpart
E would apply to all banking
organizations that meet the relevant
thresholds without reference to
completion of the parallel run process.
The final rule provides that an
advanced approaches banking
organization is one that meets the asset
size or foreign exposure thresholds for
or has opted to apply the advanced
approaches rule, without reference to
whether that banking organization has
completed the parallel run process and
has received notification from its
primary Federal supervisor pursuant to
section 121(d) of subpart E of the final
rule. The agencies have also clarified in
the final rule when completion of the
parallel run process and receipt of
notification from the primary Federal
supervisor pursuant to section 121(d) of
subpart E is necessary for an advanced
approaches banking organization to
comply with a particular aspect of the
rules. For example, only an advanced
approaches banking organization that
has completed parallel run and received
notification from its primary Federal
supervisor under section 121(d) of
subpart E must make the disclosures set
forth under subpart E of the final rule.
However, an advanced approaches
banking organization must recognize
most components of AOCI in common
equity tier 1 capital and must meet the
supplementary leverage ratio when
applicable without reference to whether
the banking organization has completed
its parallel run process.
Beginning on January 1, 2015,
banking organizations that are not
subject to the advanced approaches rule,
as well as advanced approaches banking
organizations that are covered SLHCs,
become subject to: The revised
definitions of regulatory capital; the
new minimum regulatory capital ratios;
and the regulatory capital adjustments
and deductions according to the
transition provisions.34 All banking
organizations must begin calculating
standardized total risk-weighted assets
in accordance with subpart D of the
final rule, and if applicable, the revised
34 Prior to January 1, 2015, such banking
organizations, other than covered SLHCs, must
continue to use the agencies’ general risk-based
capital rules and tier 1 leverage rules.
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market risk rule under subpart F, on
January 1, 2015.35
Beginning on January 1, 2014,
advanced approaches banking
organizations that are not SLHCs must
begin the transition period for the
revised minimum regulatory capital
ratios, definitions of regulatory capital,
and regulatory capital adjustments and
deductions established under the final
rule. The revisions to the advanced
approaches risk-weighted asset
calculations will become effective on
January 1, 2014.
From January 1, 2014 to December 31,
2014, an advanced approaches banking
organization that is on parallel run must
calculate risk-weighted assets using the
general risk-based capital rules and
substitute such risk-weighted assets for
its standardized total risk-weighted
assets for purposes of determining its
risk-based capital ratios. An advanced
approaches banking organization on
parallel run must also calculate
advanced approaches total riskweighted assets using the advanced
approaches rule in subpart E of the final
rule for purposes of confidential
reporting to its primary Federal
supervisor on the Federal Financial
Institutions Examination Council’s
(FFIEC) 101 report. An advanced
approaches banking organization that
has completed the parallel run process
and that has received notification from
its primary Federal supervisor pursuant
to section 121(d) of subpart E will
calculate its risk-weighted assets using
the general risk-based capital rules and
substitute such risk-weighted assets for
its standardized total risk-weighted
assets and also calculate advanced
approaches total risk-weighted assets
using the advanced approaches rule in
62029
subpart E of the final rule for purposes
of determining its risk-based capital
ratios from January 1, 2014 to December
31, 2014. Regardless of an advanced
approaches banking organization’s
parallel run status, on January 1, 2015,
the banking organization must begin to
apply subpart D, and if applicable,
subpart F, of the final rule to determine
its standardized total risk-weighted
assets.
The transition period for the capital
conservation and countercyclical capital
buffers for all banking organizations will
begin on January 1, 2016.
A banking organization that is
required to comply with the market risk
rule must comply with the revised
market risk rule (subpart F) as of the
same date that it must comply with
other aspects of the rule for determining
its total risk-weighted assets.
Date
Banking organizations not subject to the advanced approaches rule and
banking organizations that are covered SLHCs *
January 1, 2015 .................
January 1, 2016 .................
Begin compliance with the revised minimum regulatory capital ratios and begin the transition period for the revised
definitions of regulatory capital and the revised regulatory capital adjustments and deductions.
Begin compliance with the standardized approach for determining risk-weighted assets.
Begin the transition period for the capital conservation and countercyclical capital buffers.
Date
Advanced approaches banking organizations that are not SLHCs *
January 1, 2014 .................
Begin the transition period for the revised minimum regulatory capital ratios, definitions of regulatory capital, and
regulatory capital adjustments and deductions.
Begin compliance with the revised advanced approaches rule for determining risk-weighted assets.
Begin compliance with the standardized approach for determining risk-weighted assets.
Begin the transition period for the capital conservation and countercyclical capital buffers.
January 1, 2015 .................
January 1, 2016 .................
* If applicable, banking organizations must use the calculations in subpart F of the final rule (market risk) concurrently with the calculation of
risk-weighted assets according either to subpart D (standardized approach) or subpart E (advanced approaches) of the final rule.
A. Minimum Risk-Based Capital Ratios
and Other Regulatory Capital Provisions
Consistent with Basel III, the
proposed rule would have required
banking organizations to comply with
the following minimum capital ratios: a
common equity tier 1 capital to riskweighted assets ratio of 4.5 percent; a
tier 1 capital to risk-weighted assets
ratio of 6 percent; a total capital to riskweighted assets ratio of 8 percent; a
leverage ratio of 4 percent; and for
advanced approaches banking
organizations only, a supplementary
leverage ratio of 3 percent. The common
equity tier 1 capital ratio is a new
minimum requirement designed to
ensure that banking organizations hold
sufficient high-quality regulatory capital
that is available to absorb losses on a
going-concern basis. The proposed
capital ratios would apply to a banking
organization on a consolidated basis.
The agencies received a substantial
number of comments on the proposed
minimum risk-based capital
requirements. Several commenters
supported the proposal to increase the
minimum tier 1 risk-based capital
requirement. Other commenters
commended the agencies and the FDIC
for proposing to implement a minimum
capital requirement that focuses
primarily on common equity. These
commenters argued that common equity
is the strongest form of capital and that
the proposed minimum common equity
tier 1 capital ratio of 4.5 percent would
promote the safety and soundness of the
banking industry.
Other commenters provided general
support for the proposed increases in
minimum risk-based capital
requirements, but expressed concern
that the proposals could present unique
35 The revised PCA thresholds, discussed further
in section IV.E of this preamble, become effective
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challenges to mutual institutions
because they can only raise common
equity through retained earnings. A
number of commenters asserted that the
objectives of the proposal could be
achieved through regulatory
mechanisms other than the proposed
risk-based capital requirements,
including enhanced safety and
soundness examinations, more stringent
underwriting standards, and alternative
measures of capital.
Other commenters objected to the
proposed increase in the minimum tier
1 capital ratio and the implementation
of a common equity tier 1 capital ratio.
One commenter indicated that increases
in regulatory capital ratios would
severely limit growth at many
community banking organizations and
could encourage consolidation through
mergers and acquisitions. Other
commenters stated that for banks under
$750 million in total assets, increased
for all insured depository institutions on January 1,
2015.
IV. Minimum Regulatory Capital
Ratios, Additional Capital
Requirements, and Overall Capital
Adequacy
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compliance costs would not allow them
to provide a reasonable return to
shareholders, and thus would force
them to consolidate. Several
commenters urged the agencies and the
FDIC to recognize community banking
organizations’ limited access to the
capital markets and related difficulties
raising capital to comply with the
proposal.
One banking organization indicated
that implementation of the common
equity tier 1 capital ratio would
significantly reduce its capacity to grow
and recommended that the proposal
recognize differences in the risk and
complexity of banking organizations
and provide favorable, less stringent
requirements for smaller and noncomplex institutions. Another
commenter suggested that the proposed
implementation of an additional riskbased capital ratio would confuse
market observers and recommended that
the agencies and the FDIC implement a
regulatory capital framework that allows
investors and the market to ascertain
regulatory capital from measures of
equity derived from a banking
organization’s balance sheet.
Other commenters expressed concern
that the proposed common equity tier 1
capital ratio would disadvantage MDIs
relative to other banking organizations.
According to the commenters, in order
to retain their minority-owned status,
MDIs historically maintain a relatively
high percentage of non-voting preferred
stockholders that provide long-term,
stable sources of capital. Any public
offering to increase common equity tier
1 capital levels would dilute the
minority investors owning the common
equity of the MDI and could potentially
compromise the minority-owned status
of such institutions. One commenter
asserted that, for this reason, the
implementation of the Basel III NPR
would be contrary to the statutory
mandate of section 308 of the Financial
Institutions, Reform, Recovery and
Enforcement Act (FIRREA).36
Accordingly, the commenters
encouraged the agencies and the FDIC to
exempt MDIs from the proposed
common equity tier 1 capital ratio
requirement.
The agencies believe that all banking
organizations must have an adequate
amount of loss-absorbing capital to
continue to lend to their communities
during times of economic stress, and
therefore have decided to implement the
regulatory capital requirements,
including the minimum common equity
tier 1 capital requirement, as proposed.
For the reasons described in the NPR,
36 12
U.S.C. 1463 note.
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including the experience during the
crisis with lower quality capital
instruments, the agencies do not believe
it is appropriate to maintain the general
risk-based capital rules or to rely on the
supervisory process or underwriting
standards alone. Accordingly, the final
rule maintains the minimum common
equity tier 1 capital to total riskweighted assets ratio of 4.5 percent. The
agencies have decided not to pursue the
alternative regulatory mechanisms
suggested by commenters, as such
alternatives would be difficult to
implement consistently across banking
organizations and would not necessarily
fulfill the objective of increasing the
amount and quality of regulatory capital
for all banking organizations.
In view of the concerns expressed by
commenters with respect to MDIs, the
agencies and the FDIC evaluated the
risk-based and leverage capital levels of
MDIs to determine whether the final
rule would disproportionately impact
such institutions. This analysis found
that of the 178 MDIs in existence as of
March 31, 2013, 12 currently are not
well capitalized for PCA purposes,
whereas (according to the agencies’ and
the FDIC’s estimates) 14 would not be
considered well capitalized for PCA
purposes under the final rule if it were
fully implemented without transition
today. Accordingly, the agencies do not
believe that the final rule would
disproportionately impact MDIs and are
not adopting any exemptions or special
provisions for these institutions. While
the agencies recognize MDIs may face
impediments in meeting the common
equity tier 1 capital ratio, the agencies
believe that the improvements to the
safety and soundness of these
institutions through higher capital
standards are warranted and consistent
with their obligations under section 308
of FIRREA. As a prudential matter, the
agencies have a long-established
regulatory policy that banking
organizations should hold capital
commensurate with the level and nature
of the risks to which they are exposed,
which may entail holding capital
significantly above the minimum
requirements, depending on the nature
of the banking organization’s activities
and risk profile. Section IV.G of this
preamble describes the requirement for
overall capital adequacy of banking
organizations and the supervisory
assessment of capital adequacy.
Furthermore, consistent with the
agencies’ authority under the general
risk-based capital rules and the
proposals, section 1(d) of the final rule
includes a reservation of authority that
allows a banking organization’s primary
Federal supervisor to require the
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banking organization to hold a greater
amount of regulatory capital than
otherwise is required under the final
rule, if the supervisor determines that
the regulatory capital held by the
banking organization is not
commensurate with its credit, market,
operational, or other risks. In exercising
reservation of authority under the rule,
the agencies expect to consider the size,
complexity, risk profile, and scope of
operations of the banking organization;
and whether any public benefits would
be outweighed by risk to an insured
depository institution or to the financial
system.
B. Leverage Ratio
The proposals would require a
banking organization to satisfy a
leverage ratio of 4 percent, calculated
using the proposed definition of tier 1
capital and the banking organization’s
average total consolidated assets, minus
amounts deducted from tier 1 capital.
The agencies and the FDIC also
proposed to eliminate the exception in
the agencies’ and the FDIC’s leverage
rules that provides for a minimum
leverage ratio of 3 percent for banking
organizations with strong supervisory
ratings or BHCs that are subject to the
market risk rule.
The agencies and the FDIC received a
number of comments on the proposed
leverage ratio applicable to all banking
organizations. Several of these
commenters supported the proposed
leverage ratio, stating that it serves as a
simple regulatory standard that
constrains the ability of a banking
organization to leverage its equity
capital base. Some of the commenters
encouraged the agencies and the FDIC to
consider an alternative leverage ratio
measure of tangible common equity to
tangible assets, which would exclude
non-common stock elements from the
numerator and intangible assets from
the denominator of the ratio and thus,
according to these commenters, provide
a more reliable measure of a banking
organization’s viability in a crisis.
A number of commenters criticized
the proposed removal of the 3 percent
exception to the minimum leverage ratio
requirement for certain banking
organizations. One of these commenters
argued that removal of this exception is
unwarranted in view of the cumulative
impact of the proposals and that raising
the minimum leverage ratio requirement
for the strongest banking organizations
may lead to a deleveraging by the
institutions most able to extend credit in
a safe and sound manner. In addition,
the commenters cautioned the agencies
and the FDIC that a restrictive leverage
measure, together with more stringent
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risk-based capital requirements, could
magnify the potential impact of an
economic downturn.
Several commenters suggested
modifications to the minimum leverage
ratio requirement. One commenter
suggested increasing the minimum
leverage ratio requirement for all
banking organizations to 6 percent,
whereas another commenter
recommended a leverage ratio
requirement as high as 20 percent.
Another commenter suggested a tiered
approach, with minimum leverage ratio
requirements of 6.25 percent and 8.5
percent for community banking
organizations and large banking
organizations, respectively. According
to this commenter, such an approach
could be based on the risk
characteristics of a banking
organization, including liquidity, asset
quality, and local deposit levels, as well
as its supervisory rating. Another
commenter suggested a fluid leverage
ratio requirement that would adjust
based on certain macroeconomic
variables. Under such an approach, the
agencies and the FDIC could require
banking organizations to meet a
minimum leverage ratio of 10 percent
under favorable economic conditions
and a 6 percent leverage ratio during an
economic contraction.
In addition, a number of commenters
encouraged the agencies and the FDIC to
reconsider the scope of exposures that
banking organizations include in the
denominator of the leverage ratio, which
is based on average total consolidated
assets under GAAP. Several of these
commenters criticized the proposed
minimum leverage ratio requirement
because it would not include an
exemption for certain exposures that are
unique to banking organizations
engaged in insurance activities.
Specifically, these commenters
encouraged the Board to consider
excluding assets held in separate
accounts and stated that such assets are
not available to satisfy the claims of
general creditors and do not affect the
leverage position of an insurance
company. A few commenters asserted
that the inclusion of separate account
assets in the calculation of the leverage
ratio stands in contrast to the agencies’
and the FDIC’s treatment of banking
organization’s trust accounts, bankaffiliated mutual funds, and bankmaintained common and collective
investment funds. In addition, some of
these commenters argued for a partial
exclusion of trading account assets
supporting insurance liabilities because,
according to these commenters, the risks
attributable to these assets accrue to
contract owners.
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The agencies continue to believe that
a minimum leverage ratio requirement
of 4 percent for all banking
organizations is appropriate in light of
its role as a complement to the riskbased capital ratios. The proposed
leverage ratio is more conservative than
the current leverage ratio because it
incorporates a more stringent definition
of tier 1 capital. In addition, the
agencies believe that it is appropriate for
all banking organizations, regardless of
their supervisory rating or trading
activities, to meet the same minimum
leverage ratio requirements. As a
practical matter, the agencies generally
have found a leverage ratio of less than
4 percent to be inconsistent with a
supervisory composite rating of ‘‘1.’’
Modifying the scope of the leverage
ratio measure or implementing a fluid or
tiered approach for the minimum
leverage ratio requirement would create
additional operational complexity and
variability in a minimum ratio
requirement that is intended to place a
constraint on the maximum degree to
which a banking organization can
leverage its equity base. Accordingly,
the final rule retains the existing
minimum leverage ratio requirement of
4 percent and removes the 3 percent
leverage ratio exception as of January 1,
2014 for advanced approaches banking
organizations and as of January 1, 2015
for all other banking organizations.
With respect to including separate
account assets in the leverage ratio
denominator, the Board continues to
consider this issue together with other
issues raised by commenters regarding
the regulatory capital treatment of
insurance activities. The final rule
continues to include separate account
assets in total assets, consistent with the
proposal and the leverage ratio rule for
BHCs.
C. Supplementary Leverage Ratio for
Advanced Approaches Banking
Organizations
As part of Basel III, the BCBS
introduced a minimum leverage ratio
requirement of 3 percent (the Basel III
leverage ratio) as a backstop measure to
the risk-based capital requirements,
designed to improve the resilience of
the banking system worldwide by
limiting the amount of leverage that a
banking organization may incur. The
Basel III leverage ratio is defined as the
ratio of tier 1 capital to a combination
of on- and off-balance sheet exposures.
As discussed in the Basel III NPR, the
agencies and the FDIC proposed the
supplementary leverage ratio only for
advanced approaches banking
organizations because these banking
organizations tend to have more
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significant amounts of off-balance sheet
exposures that are not captured by the
current leverage ratio. Under the
proposal, consistent with Basel III,
advanced approaches banking
organizations would be required to
maintain a minimum supplementary
leverage ratio of 3 percent of tier 1
capital to on- and off-balance sheet
exposures (total leverage exposure).
The agencies and the FDIC received a
number of comments on the proposed
supplementary leverage ratio. Several
commenters stated that the proposed
supplementary leverage ratio is
unnecessary in light of the minimum
leverage ratio requirement applicable to
all banking organizations. These
commenters stated that the
implementation of the supplementary
leverage ratio requirement would create
market confusion as to the interrelationships among the ratios and as to
which ratio serves as the binding
constraint for an individual banking
organization. One commenter noted that
an advanced approaches banking
organization would be required to
calculate eight distinct regulatory
capital ratios (common equity tier 1, tier
1, and total capital to risk-weighted
assets under the advanced approaches
and the standardized approach, as well
as two leverage ratios) and encouraged
the agencies and the FDIC to streamline
the application of regulatory capital
ratios. In addition, commenters
suggested that the agencies and the
FDIC postpone the implementation of
the supplementary leverage ratio until
January 1, 2018, after the international
supervisory monitoring process is
complete, and to collect supplementary
leverage ratio information on a
confidential basis until then.
At least one commenter encouraged
the agencies and the FDIC to consider
extending the application of the
proposed supplementary leverage ratio
on a case-by-case basis to banking
organizations with total assets of
between $50 billion and $250 billion,
stating that such institutions may have
significant off-balance sheet exposures
and engage in a substantial amount of
repo-style transactions. Other
commenters suggested increasing the
proposed supplementary leverage ratio
requirement to at least 8 percent for
BHCs, under the Board’s authority in
section 165 of the Dodd-Frank Act to
implement enhanced capital
requirements for systemically important
financial institutions.37
With respect to specific aspects of the
supplementary leverage ratio, some
37 See section 165 of the Dodd-Frank Act, 12
U.S.C. 5365.
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commenters criticized the methodology
for the total leverage exposure.
Specifically, one commenter expressed
concern that using GAAP as the basis
for determining a banking organization’s
total leverage exposure would exclude a
wide range of off-balance sheet
exposures, including derivatives and
securities lending transactions, as well
as permit extensive netting. To address
these issues, the commenter suggested
requiring advanced approaches banking
organizations to determine their total
leverage exposure using International
Financial Reporting Standards (IFRS),
asserting that it restricts netting and,
relative to GAAP, requires the
recognition of more off-balance sheet
securities lending transactions.
Several commenters criticized the
proposed incorporation of off-balance
sheet exposures into the total leverage
exposure. One commenter argued that
including unfunded commitments in
the total leverage exposure runs counter
to the purpose of the supplementary
leverage ratio as an on-balance sheet
measure of capital that complements the
risk-based capital ratios. This
commenter was concerned that the
proposed inclusion of unfunded
commitments would result in a
duplicative assessment against banking
organizations when the forthcoming
liquidity ratio requirements are
implemented in the United States. The
commenter noted that the proposed 100
percent credit conversion factor for all
unfunded commitments is not
appropriately calibrated to the vastly
different types of commitments that
exist across the industry. If the
supplementary leverage ratio is retained
in the final rule, the commenter
requested that the agencies and the
FDIC align the credit conversion factors
for unfunded commitments under the
supplementary leverage ratio and any
forthcoming liquidity ratio
requirements.
Another commenter encouraged the
agencies and the FDIC to allow
advanced approaches banking
organizations to exclude from total
leverage exposure the notional amount
of any unconditionally cancellable
commitment. According to this
commenter, unconditionally cancellable
commitments are not credit exposures
because they can be extinguished at any
time at the sole discretion of the issuing
entity. Therefore, the commenter
argued, the inclusion of these
commitments could potentially distort a
banking organization’s measure of total
leverage exposure.
A few commenters requested that the
agencies and the FDIC exclude offbalance sheet trade finance instruments
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from the total leverage exposure,
asserting that such instruments are
based on underlying client transactions
(for example, a shipment of goods) and
are generally short-term. The
commenters argued that trade finance
instruments do not create excessive
systemic leverage and that they are
liquidated by fulfillment of the
underlying transaction and payment at
maturity. Another commenter requested
that the agencies and the FDIC apply the
same credit conversion factors to trade
finance instruments as under the
general risk-based capital rules—that is,
20 percent of the notional value for
trade-related contingent items that arise
from the movement of goods, and 50
percent of the notional value for
transaction-related contingent items,
including performance bonds, bid
bonds, warranties, and performance
standby letters of credit. According to
this commenter, such an approach
would appropriately consider the lowrisk characteristics of these instruments
and ensure price stability in trade
finance.
Several commenters supported the
proposed treatment for repo-style
transactions (including repurchase
agreements, securities lending and
borrowing transactions, and reverse
repos). These commenters stated that
securities lending transactions are fully
collateralized and marked to market
daily and, therefore, the on-balance
sheet amounts generated by these
transactions appropriately capture the
exposure for purposes of the
supplementary leverage ratio. These
commenters also supported the
proposed treatment for indemnified
securities lending transactions and
encouraged the agencies and the FDIC to
retain this treatment in the final rule.
Other commenters stated that the
proposed measurement of repo-style
transactions is not sufficiently
conservative and recommended that the
agencies and the FDIC implement a
methodology that includes in total
leverage exposure the notional amounts
of these transactions.
A few commenters raised concerns
about the proposed methodology for
determining the exposure amount of
derivative contracts. Some commenters
criticized the agencies and the FDIC for
not allowing advanced approaches
banking organizations to use the
internal models methodology to
calculate the exposure amount for
derivative contracts. According to these
commenters, the agencies and the FDIC
should align the methods for calculating
exposure for derivative contracts for
purposes of the supplementary leverage
ratio and the advanced approaches risk-
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based capital ratios to more
appropriately reflect the riskmanagement activities of advanced
approaches banking organizations and
to measure these exposures consistently
across the regulatory capital ratios. At
least one commenter requested
clarification of the proposed treatment
of collateral received in connection with
derivative contracts. This commenter
also encouraged the agencies and the
FDIC to permit recognition of eligible
collateral for purposes of reducing total
leverage exposure, consistent with
proposed legislation in other BCBS
member jurisdictions.
The introduction of an international
leverage ratio requirement in the Basel
III capital framework is an important
development that would provide a
consistent leverage ratio measure across
internationally-active institutions.
Furthermore, the supplementary
leverage ratio is reflective of the on- and
off-balance sheet activities of large,
internationally active banking
organizations. Accordingly, consistent
with Basel III, the final rule implements
for reporting purposes the proposed
supplementary leverage ratio for
advanced approaches banking
organizations starting on January 1,
2015 and requires advanced approaches
banking organizations to comply with
the minimum supplementary leverage
ratio requirement starting on January 1,
2018. Public reporting of the
supplementary leverage ratio during the
international supervisory monitoring
period is consistent with the
international implementation timeline
and enables transparency and
comparability of reporting the leverage
ratio requirement across jurisdictions.
The agencies are not applying the
supplementary leverage ratio
requirement to banking organizations
that are not subject to the advanced
approaches rule in the final rule.
Applying the supplementary leverage
ratio routinely could create operational
complexity for smaller banking
organizations that are not
internationally active, and that generally
do not have off-balance sheet activities
that are as extensive as banking
organizations that are subject to the
advanced approaches rule. The agencies
note that the final rule imposes riskbased capital requirements on all repostyle transactions and otherwise
imposes constraints on all banking
organizations’ off-balance sheet
exposures.
With regard to the commenters’ views
to require the use of IFRS for purposes
of the supplementary leverage ratio, the
agencies note that the use of GAAP in
the final rule as a starting point to
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measure exposure of certain derivatives
and repo-style transactions, has the
advantage of maintaining consistency
between regulatory capital calculations
and regulatory reporting, the latter of
which must be consistent with GAAP
or, if another accounting principle is
used, no less stringent than GAAP.38
In response to the commenters’ views
regarding the scope of the total leverage
exposure, the agencies note that the
supplementary leverage ratio is
intended to capture on- and off-balance
sheet exposures of a banking
organization. Commitments represent an
agreement to extend credit and thus
including commitments (both funded
and unfunded) in the supplementary
leverage ratio is consistent with its
purpose to measure the on- and offbalance sheet leverage of a banking
organization, as well as with safety and
soundness principles. Accordingly, the
agencies believe that total leverage
exposure should include banking
organizations’ off-balance sheet
exposures, including all loan
commitments that are not
unconditionally cancellable, financial
standby letters of credit, performance
standby letters of credit, and
commercial and other similar letters of
credit.
The proposal to include
unconditionally cancellable
commitments in the total leverage
exposure recognizes that a banking
organization may extend credit under
the commitment before it is cancelled.
If the banking organization exercises its
option to cancel the commitment, its
total leverage exposure amount with
respect to the commitment will be
limited to any extension of credit prior
to cancellation. The proposal
considered banking organizations’
ability to cancel such commitments and,
therefore, limited the amount of
unconditionally cancellable
commitments included in total leverage
exposure to 10 percent of the notional
amount of such commitments.
The agencies note that the credit
conversion factors used in the
supplementary leverage ratio and in any
forthcoming liquidity ratio requirements
have been developed to serve the
purposes of the respective frameworks
and may not be identical. Similarly, the
commenters’ proposed modifications to
credit conversion factors for trade
finance transactions would be
inconsistent with the purpose of the
supplementary leverage ratio—to
capture all off-balance sheet exposures
of banking organizations in a primarily
non-risk-based manner.
38 See
12 U.S.C. 1831n(a)(2).
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For purposes of incorporating
derivative contracts in the total leverage
exposure, the proposal would require all
advanced approaches banking
organizations to use the same
methodology to measure such
exposures. The proposed approach
provides a uniform measure of exposure
for derivative contracts across banking
organizations, without regard to their
models. Accordingly, the agencies do
not believe a banking organization
should be permitted to use internal
models to measure the exposure amount
of derivative contracts for purposes of
the supplementary leverage ratio.
With regard to commenters requesting
a modification of the proposed
treatment for repo-style transactions, the
agencies do not believe that the
proposed modifications are warranted at
this time because international
discussions and quantitative analysis of
the exposure measure for repo-style
transactions are still ongoing.
The agencies are continuing to work
with the BCBS to assess the Basel III
leverage ratio, including its calibration
and design, as well as the impact of any
differences in national accounting
frameworks material to the denominator
of the Basel III leverage ratio. The
agencies will consider any changes to
the supplementary leverage ratio as the
BCBS revises the Basel III leverage ratio.
Therefore, the agencies have adopted
the proposed supplementary leverage
ratio in the final rule without
modification. An advanced approaches
banking organization must calculate the
supplementary leverage ratio as the
simple arithmetic mean of the ratio of
the banking organization’s tier 1 capital
to total leverage exposure as of the last
day of each month in the reporting
quarter. The agencies also note that
collateral may not be applied to reduce
the potential future exposure (PFE)
amount for derivative contracts.
Under the final rule, total leverage
exposure equals the sum of the
following:
(1) The balance sheet carrying value
of all of the banking organization’s onbalance sheet assets less amounts
deducted from tier 1 capital under
section 22(a), (c), and (d) of the final
rule;
(2) The PFE amount for each
derivative contract to which the banking
organization is a counterparty (or each
single-product netting set of such
transactions) determined in accordance
with section 34 of the final rule, but
without regard to section 34(b);
(3) 10 percent of the notional amount
of unconditionally cancellable
commitments made by the banking
organization; and
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(4) The notional amount of all other
off-balance sheet exposures of the
banking organization (excluding
securities lending, securities borrowing,
reverse repurchase transactions,
derivatives and unconditionally
cancellable commitments).
Advanced approaches banking
organizations must maintain a
minimum supplementary leverage ratio
of 3 percent beginning on January 1,
2018, consistent with Basel III.
However, as noted above, beginning on
January 1, 2015, advanced approaches
banking organizations must calculate
and report their supplementary leverage
ratio.
D. Capital Conservation Buffer
During the recent financial crisis,
some banking organizations continued
to pay dividends and substantial
discretionary bonuses even as their
financial condition weakened. Such
capital distributions had a significant
negative impact on the overall strength
of the banking sector. To encourage
better capital conservation by banking
organizations and to enhance the
resilience of the banking system, the
proposed rule would have limited
capital distributions and discretionary
bonus payments for banking
organizations that do not hold a
specified amount of common equity tier
1 capital in addition to the amount of
regulatory capital necessary to meet the
minimum risk-based capital
requirements (capital conservation
buffer), consistent with Basel III. In this
way, the capital conservation buffer is
intended to provide incentives for
banking organizations to hold sufficient
capital to reduce the risk that their
capital levels would fall below their
minimum requirements during a period
of financial stress.
The proposed rules incorporated a
capital conservation buffer composed of
common equity tier 1 capital in addition
to the minimum risk-based capital
requirements. Under the proposal, a
banking organization would need to
hold a capital conservation buffer in an
amount greater than 2.5 percent of total
risk-weighted assets (plus, for an
advanced approaches banking
organization, 100 percent of any
applicable countercyclical capital buffer
amount) to avoid limitations on capital
distributions and discretionary bonus
payments to executive officers, as
defined in the proposal. The proposal
provided that the maximum dollar
amount that a banking organization
could pay out in the form of capital
distributions or discretionary bonus
payments during the current calendar
quarter (the maximum payout amount)
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would be equal to a maximum payout
ratio, multiplied by the banking
organization’s eligible retained income,
as discussed below. The proposal
provided that a banking organization
with a buffer of more than 2.5 percent
of total risk-weighted assets (plus, for an
advanced approaches banking
organization, 100 percent of any
applicable countercyclical capital
buffer), would not be subject to a
maximum payout amount. The proposal
clarified that the agencies and the FDIC
reserved the ability to restrict capital
distributions under other authorities
and that restrictions on capital
distributions and discretionary bonus
payments associated with the capital
conservation buffer would not be part of
the PCA framework. The calibration of
the buffer is supported by an evaluation
of the loss experience of U.S. banking
organizations as part of an analysis
conducted by the BCBS, as well as by
evaluation of historical levels of capital
at U.S. banking organizations.39
The agencies and the FDIC received a
significant number of comments on the
proposed capital conservation buffer. In
general, the commenters characterized
the capital conservation buffer as overly
conservative, and stated that the
aggregate amount of capital that would
be required for a banking organization to
avoid restrictions on dividends and
discretionary bonus payments under the
proposed rule exceeded the amount
required for a safe and prudent banking
system. Commenters expressed concern
that the capital conservation buffer
could disrupt the priority of payments
in a banking organization’s capital
structure, as any restrictions on
dividends would apply to both common
and preferred stock. Commenters also
questioned the appropriateness of
restricting a banking organization that
fails to comply with the capital
conservation buffer from paying
dividends or bonus payments if it has
established and maintained cash
reserves to cover future uncertainty.
One commenter supported the
establishment of a formal mechanism
for banking organizations to request
agency approval to make capital
distributions even if doing so would
otherwise be restricted under the capital
conservation buffer.
Other commenters recommended an
exemption from the proposed capital
conservation buffer for certain types of
banking organizations, such as
community banking organizations,
39 ‘‘Calibrating regulatory capital requirements
and buffers: A top-down approach.’’ Basel
Committee on Banking Supervision, October, 2010,
available at www.bis.org.
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banking organizations organized in
mutual form, and rural BHCs that rely
heavily on bank stock loans for growth
and expansion purposes. Commenters
also recommended a wide range of
institutions that should be excluded
from the buffer based on a potential size
threshold, such as banking
organizations with total consolidated
assets of less than $250 billion.
Commenters also recommended that Scorporations be exempt from the
proposed capital conservation buffer
because under the U.S. Internal Revenue
Code, S-corporations are not subject to
a corporate-level tax; instead, Scorporation shareholders must report
income and pay income taxes based on
their share of the corporation’s profit or
loss. An S-corporation generally
declares a dividend to help shareholders
pay their tax liabilities that arise from
reporting their share of the corporation’s
profits. According to some commenters,
the proposal disadvantaged Scorporations because shareholders of Scorporations would be liable for tax on
the S-corporation’s net income, and the
S-corporation may be prohibited from
making a dividend to these shareholders
to fund the tax payment.
One commenter criticized the
proposed composition of the capital
conservation buffer (which must consist
solely of common equity tier 1 capital)
and encouraged the agencies and the
FDIC to allow banking organizations to
include noncumulative perpetual
preferred stock and other tier 1 capital
instruments. Several commenters
questioned the empirical basis for a
capital conservation buffer of 2.5
percent, and encouraged the agencies
and the FDIC to provide a quantitative
analysis for the proposal. One
commenter suggested application of the
capital conservation buffer only during
economic downturn scenarios,
consistent with the agencies’ and the
FDIC’s objective to restrict dividends
and discretionary bonus payments
during these periods. According to this
commenter, a banking organization that
fails to maintain a sufficient capital
conservation buffer during periods of
economic stress also could be required
to submit a plan to increase its capital.
After considering these comments, the
agencies have decided to maintain
common equity tier 1 capital as the
basis of the capital conservation buffer
and to apply the capital conservation
buffer to all types of banking
organizations at all times. Application
of the buffer to all types of banking
organizations and maintenance of a
capital buffer during periods of market
and economic stability is appropriate to
encourage sound capital management
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and help ensure that banking
organizations will maintain adequate
amounts of loss-absorbing capital going
forward, strengthening the ability of the
banking system to continue serving as a
source of credit to the economy in times
of stress. A buffer framework that
restricts dividends and discretionary
bonus payments only for certain types
of banking organizations or only during
an economic contraction would not
achieve these objectives. Similarly,
basing the capital conservation buffer on
the most loss-absorbent form of capital
is most consistent with the purpose of
the capital conservation buffer as it
helps to ensure that the buffer can be
used effectively by banking
organizations at a time when they are
experiencing losses.
The agencies recognize that Scorporation banking organizations
structure their tax payments differently
from C corporations. However, the
agencies note that this distinction
results from S-corporations’ passthrough taxation, in which profits are
not subject to taxation at the corporate
level, but rather at the shareholder level.
The agencies are charged with
evaluating the capital levels and safety
and soundness of the banking
organization. At the point where a
decrease in the organization’s capital
triggers dividend restrictions, the
agencies believe that capital should stay
within the banking organization. Scorporation shareholders may receive a
benefit from pass-through taxation, but
with that benefit comes the risk that the
corporation has no obligation to make
dividend distributions to help
shareholders pay their tax liabilities.
Therefore, the final rule does not
exempt S-corporations from the capital
conservation buffer.
Accordingly, under the final rule a
banking organization must maintain a
capital conservation buffer of common
equity tier 1 capital in an amount
greater than 2.5 percent of total riskweighted assets (plus, for an advanced
approaches banking organization, 100
percent of any applicable
countercyclical capital buffer amount)
to avoid being subject to limitations on
capital distributions and discretionary
bonus payments to executive officers.
The proposal defined eligible retained
income as a banking organization’s net
income (as reported in the banking
organization’s quarterly regulatory
reports) for the four calendar quarters
preceding the current calendar quarter,
net of any capital distributions and
associated tax effects not already
reflected in net income. The agencies
and the FDIC received a number of
comments regarding the proposed
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definition of eligible retained income,
which is used to calculate the maximum
payout amount. Some commenters
suggested that the agencies and the
FDIC limit capital distributions based
on retained earnings instead of eligible
retained income, citing the Board’s
Regulation H as an example of this
regulatory practice.40 Several
commenters representing banking
organizations organized as Scorporations recommended revisions to
the definition of eligible retained
income so that it would be net of passthrough tax distributions to
shareholders that have made a passthrough election for tax purposes,
allowing S-corporation shareholders to
pay their tax liability notwithstanding
any dividend restrictions resulting from
failure to comply with the capital
conservation buffer. Some commenters
suggested that the definition of eligible
retained income be adjusted for items
such as goodwill impairment that are
captured in the definition of ‘‘net
income’’ for regulatory reporting
purposes but which do not affect
regulatory capital.
The final rule adopts the proposed
definition of eligible retained income
without change. The agencies believe
the commenters’ suggested
modifications to the definition of
eligible retained income would add
complexity to the final rule and in some
cases may be counter-productive by
weakening the incentives of the capital
conservation buffer. The agencies note
that the definition of eligible retained
income appropriately accounts for
impairment charges, which reduce
eligible retained income but also reduce
the balance sheet amount of goodwill
that is deducted from regulatory capital.
Further, the proposed definition of
eligible retained income, which is based
on net income as reported in the
banking organization’s quarterly
regulatory reports, reflects a simple
measure of a banking organization’s
recent performance upon which to base
restrictions on capital distributions and
discretionary payments to executive
officers. For the same reasons as
described above regarding the
application of the capital conservation
buffer to S-corporations generally, the
agencies have determined that the
definition of eligible retained income
should not be modified to address the
tax-related concerns raised by
commenters writing on behalf of Scorporations.
The proposed rule generally defined a
capital distribution as a reduction of tier
1 or tier 2 capital through the
40 See
12 CFR part 208.
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repurchase or redemption of a capital
instrument or by other means; a
dividend declaration or payment on any
tier 1 or tier 2 capital instrument if the
banking organization has full discretion
to permanently or temporarily suspend
such payments without triggering an
event of default; or any similar
transaction that the primary Federal
supervisor determines to be in
substance a distribution of capital.
Commenters provided suggestions on
the definition of ‘‘capital distribution.’’
One commenter requested that a
‘‘capital distribution’’ be defined to
exclude any repurchase or redemption
to the extent the capital repurchased or
redeemed was replaced in a
contemporaneous transaction by the
issuance of capital of an equal or higher
quality tier. The commenter maintained
that the proposal would unnecessarily
penalize banking organizations that
redeem capital but contemporaneously
replace such capital with an equal or
greater amount of capital of an
equivalent or higher quality. In response
to comments, and recognizing that
redeeming capital instruments that are
replaced with instruments of the same
or similar quality does not weaken a
banking organization’s overall capital
position, the final rule provides that a
redemption or repurchase of a capital
instrument is not a distribution
provided that the banking organization
fully replaces that capital instrument by
issuing another capital instrument of the
same or better quality (that is, more
subordinate) based on the final rule’s
eligibility criteria for capital
instruments, and provided that such
issuance is completed within the same
calendar quarter the banking
organization announces the repurchase
or redemption. For purposes of this
definition, a capital instrument is issued
at the time that it is fully paid in. For
purposes of the final rule, the agencies
changed the defined term from ‘‘capital
distribution’’ to ‘‘distribution’’ to avoid
confusion with the term ‘‘capital
distribution’’ used in the Board’s capital
plan rule.41
The proposed rule defined
discretionary bonus payment as a
payment made to an executive officer of
a banking organization (as defined
below) that meets the following
conditions: the banking organization
retains discretion as to the fact of the
payment and as to the amount of the
payment until the payment is awarded
to the executive officer; the amount paid
is determined by the banking
organization without prior promise to,
or agreement with, the executive officer;
41 See
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and the executive officer has no
contractual right, express or implied, to
the bonus payment.
The agencies and the FDIC received a
number of comments on the proposed
definition of discretionary bonus
payments to executive officers. One
commenter expressed concern that the
proposed definition of discretionary
bonus payment may not be effective
unless the agencies and the FDIC
provided clarification as to the type of
payments covered, as well as the timing
of such payments. This commenter
asked whether the proposed rule would
prohibit the establishment of a prefunded bonus pool with mandatory
distributions and sought clarification as
to whether non-cash compensation
payments, such as stock options, would
be considered a discretionary bonus
payment.
The final rule’s definition of
discretionary bonus payment is
unchanged from the proposal. The
agencies note that if a banking
organization prefunds a pool for
bonuses payable under a contract, the
bonus pool is not discretionary and,
therefore, is not subject to the capital
conservation buffer limitations. In
addition, the definition of discretionary
bonus payment does not include noncash compensation payments that do
not affect capital or earnings such as, in
some cases, stock options.
Commenters representing community
banking organizations maintained that
the proposed restrictions on
discretionary bonus payments would
disproportionately impact such
institutions’ ability to attract and retain
qualified employees. One commenter
suggested revising the proposed rule so
that a banking organization that fails to
satisfy the capital conservation buffer
would be restricted from making a
discretionary bonus payment only to the
extent it exceeds 15 percent of the
employee’s salary, asserting that this
would prevent excessive bonus
payments while allowing community
banking organizations flexibility to
compensate key employees. The final
rule does not incorporate this
suggestion. The agencies note that the
potential limitations and restrictions
under the capital conservation buffer
framework do not automatically
translate into a prohibition on
discretionary bonus payments. Instead,
the overall dollar amount of dividends
and bonuses to executive officers is
capped based on how close the banking
organization’s regulatory capital ratios
are to its minimum capital ratios and on
the earnings of the banking organization
that are available for distribution. This
approach provides appropriate
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incentives for capital conservation
while preserving flexibility for
institutions to decide how to allocate
income available for distribution
between discretionary bonus payments
and other distributions.
The proposal defined executive
officer as a person who holds the title
or, without regard to title, salary, or
compensation, performs the function of
one or more of the following positions:
President, chief executive officer,
executive chairman, chief operating
officer, chief financial officer, chief
investment officer, chief legal officer,
chief lending officer, chief risk officer,
or head of a major business line, and
other staff that the board of directors of
the banking organization deems to have
equivalent responsibility.42
Commenters generally supported a
more restrictive definition of executive
officer, arguing that the definition of
executive officer should be no broader
than the definition under the Board’s
Regulation O,43 which governs any
extension of credit between a member
bank and an executive officer, director,
or principal shareholder. Some
commenters, however, favored a more
expansive definition of executive
officer, with one commenter supporting
the inclusion of directors of the banking
organization or directors of any of the
banking organization’s affiliates, any
other person in control of the banking
organization or the banking
organizations’ affiliates, and any person
in control of a major business line. In
accordance with the agencies’ objective
to include those individuals within a
banking organization with the greatest
responsibility for the organization’s
financial condition and risk exposure,
the final rule maintains the definition of
executive officer as proposed.
Under the proposal, advanced
approaches banking organizations
would have calculated their capital
conservation buffer (and any applicable
countercyclical capital buffer amount)
using their advanced approaches total
risk-weighted assets. Several
commenters supported this aspect of the
proposal, and one stated that the
methodologies for calculating riskweighted assets under the advanced
approaches rule would more effectively
capture the individual risk profiles of
such banking organizations, asserting
further that advanced approaches
banking organizations would face a
competitive disadvantage relative to
foreign banking organizations if they
were required to use standardized total
42 See 76 FR 21170 (April 14, 2011) for a
comparable definition of ‘‘executive officer.’’
43 See 12 CFR part 215.
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risk-weighted assets to determine
compliance with the capital
conservation buffer. In contrast, another
commenter suggested that advanced
approaches banking organizations be
allowed to use the advanced approaches
methodologies as the basis for
calculating the capital conservation
buffer only when it would result in a
more conservative outcome than under
the standardized approach in order to
maintain competitive equity
domestically. Another commenter
expressed concerns that the capital
conservation buffer is based only on
risk-weighted assets and recommended
additional application of a capital
conservation buffer to the leverage ratio
to avoid regulatory arbitrage
opportunities and to accomplish the
agencies’ and the FDIC’s stated objective
of ensuring that banking organizations
have sufficient capital to absorb losses.
The final rule requires that advanced
approaches banking organizations that
have completed the parallel run process
and that have received notification from
their primary Federal supervisor
pursuant to section 121(d) of subpart E
use their risk-based capital ratios under
section 10 of the final rule (that is, the
lesser of the standardized and the
advanced approaches ratios) as the basis
for calculating their capital conservation
buffer (and any applicable
countercyclical capital buffer). The
agencies believe such an approach is
appropriate because it is consistent with
how advanced approaches banking
organizations compute their minimum
risk-based capital ratios.
Many commenters discussed the
interplay between the proposed capital
conservation buffer and the PCA
framework. Some commenters
encouraged the agencies and the FDIC to
reset the buffer requirement to two
percent of total risk-weighted assets in
order to align it with the margin
between the ‘‘adequately-capitalized’’
category and the ‘‘well-capitalized’’
category under the PCA framework.
Similarly, some commenters
characterized the proposal as confusing
because a banking organization could be
considered well capitalized for PCA
purposes, but at the same time fail to
maintain a sufficient capital
conservation buffer and be subject to
restrictions on capital distributions and
discretionary bonus payments. These
commenters encouraged the agencies
and the FDIC to remove the capital
conservation buffer for purposes of the
final rule, and instead use their existing
authority to impose restrictions on
dividends and discretionary bonus
payments on a case-by-case basis
through formal enforcement actions.
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Several commenters stated that
compliance with a capital conservation
buffer that operates outside the
traditional PCA framework adds
complexity to the final rule, and
suggested increasing minimum capital
requirements if the agencies and the
FDIC determine they are currently
insufficient. Specifically, one
commenter encouraged the agencies and
the FDIC to increase the minimum total
risk-based capital requirement to 10.5
percent and remove the capital
conservation buffer from the rule.
The capital conservation buffer has
been designed to give banking
organizations the flexibility to use the
buffer while still being well capitalized.
Banking organizations that maintain
their risk-based capital ratios at least 50
basis points above the well capitalized
PCA levels will not be subject to any
restrictions imposed by the capital
conservation buffer, as applicable. As
losses begin to accrue or a banking
organization’s risk-weighted assets
begin to grow such that the capital ratios
of a banking organization are below the
capital conservation buffer but above
the well capitalized thresholds, the
incremental limitations on distributions
are unlikely to affect planned capital
distributions or discretionary bonus
payments but may provide a check on
rapid expansion or other activities that
would weaken the organization’s capital
position.
Under the final rule, the maximum
payout ratio is the percentage of eligible
retained income that a banking
organization is allowed to pay out in the
form of distributions and discretionary
bonus payments, each as defined under
the rule, during the current calendar
quarter. The maximum payout ratio is
determined by the banking
organization’s capital conservation
buffer as calculated as of the last day of
the previous calendar quarter.
A banking organization’s capital
conservation buffer is the lowest of the
following ratios: (i) The banking
organization’s common equity tier 1
capital ratio minus its minimum
common equity tier 1 capital ratio; (ii)
the banking organization’s tier 1 capital
ratio minus its minimum tier 1 capital
ratio; and (iii) the banking
organization’s total capital ratio minus
its minimum total capital ratio. If the
banking organization’s common equity
tier 1, tier 1 or total capital ratio is less
than or equal to its minimum common
equity tier 1, tier 1 or total capital ratio,
respectively, the banking organization’s
capital conservation buffer is zero.
The mechanics of the capital
conservation buffer under the final rule
are unchanged from the proposal. A
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banking organization’s maximum
payout amount for the current calendar
quarter is equal to the banking
organization’s eligible retained income,
multiplied by the applicable maximum
payout ratio, in accordance with Table
1. A banking organization with a capital
conservation buffer that is greater than
2.5 percent (plus, for an advanced
approaches banking organization, 100
percent of any applicable
countercyclical capital buffer) is not
subject to a maximum payout amount as
a result of the application of this
provision. However, a banking
organization may otherwise be subject
to limitations on capital distributions as
a result of supervisory actions or other
laws or regulations.44
Table 1 illustrates the relationship
between the capital conservation buffer
and the maximum payout ratio. The
maximum dollar amount that a banking
organization is permitted to pay out in
62037
the form of distributions or
discretionary bonus payments during
the current calendar quarter is equal to
the maximum payout ratio multiplied
by the banking organization’s eligible
retained income. The calculation of the
maximum payout amount is made as of
the last day of the previous calendar
quarter and any resulting restrictions
apply during the current calendar
quarter.
TABLE 1—CAPITAL CONSERVATION BUFFER AND MAXIMUM PAYOUT RATIO 45
Capital conservation buffer (as a percentage of standardized or advanced total risk-weighted assets,
as applicable)
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Greater than 2.5 percent ..........................................................................................................................
Less than or equal to 2.5 percent, and greater than 1.875 percent .......................................................
Less than or equal to 1.875 percent, and greater than 1.25 percent .....................................................
Less than or equal to 1.25 percent, and greater than 0.625 percent .....................................................
Less than or equal to 0.625 percent ........................................................................................................
Maximum payout ratio (as a percentage
of eligible retained income)
No payout ratio limitation applies.
60 percent.
40 percent.
20 percent.
0 percent.
Table 1 illustrates that the capital
conservation buffer requirements are
divided into equal quartiles, each
associated with increasingly stringent
limitations on distributions and
discretionary bonus payments to
executive officers as the capital
conservation buffer approaches zero. As
described in the next section, each
quartile expands proportionately for
advanced approaches banking
organizations when the countercyclical
capital buffer amount is greater than
zero. In a scenario where a banking
organization’s risk-based capital ratios
fall below its minimum risk-based
capital ratios plus 2.5 percent of total
risk-weighted assets, the maximum
payout ratio also would decline. A
banking organization that becomes
subject to a maximum payout ratio
remains subject to restrictions on capital
distributions and certain discretionary
bonus payments until it is able to build
up its capital conservation buffer
through retained earnings, raising
additional capital, or reducing its riskweighted assets. In addition, as a
general matter, a banking organization
cannot make distributions or certain
discretionary bonus payments during
the current calendar quarter if the
banking organization’s eligible retained
income is negative and its capital
conservation buffer was less than 2.5
percent as of the end of the previous
quarter.
Compliance with the capital
conservation buffer is determined prior
to any distribution or discretionary
bonus payment. Therefore, a banking
organization with a capital buffer of
more than 2.5 percent is not subject to
any restrictions on distributions or
discretionary bonus payments even if
such distribution or payment would
result in a capital buffer of less than or
equal to 2.5 percent in the current
calendar quarter. However, to remain
free of restrictions for purposes of any
subsequent quarter, the banking
organization must restore capital to
increase the buffer to more than 2.5
percent prior to any distribution or
discretionary bonus payment in any
subsequent quarter.
In the proposal, the agencies and the
FDIC solicited comment on the impact,
if any, of prohibiting a banking
organization that is subject to a
maximum payout ratio of zero percent
from making a penny dividend to
common stockholders. One commenter
stated that such banking organizations
should be permitted to pay a penny
dividend on their common stock
notwithstanding the limitations
imposed by the capital conservation
buffer. This commenter maintained that
the inability to pay any dividend on
common stock could make it more
difficult to attract equity investors such
as pension funds that often are required
to invest only in institutions that pay a
quarterly dividend. While the agencies
did not incorporate a blanket exemption
for penny dividends on common stock,
under the final rule, as under the
proposal, the primary Federal
supervisor may permit a banking
organization to make a distribution or
discretionary bonus payment if the
primary Federal supervisor determines
that such distribution or payment would
not be contrary to the purpose of the
capital conservation buffer or the safety
and soundness of the organization. In
making such determinations, the
primary Federal supervisor would
consider the nature of and
circumstances giving rise to the request.
44 See, e.g., 12 U.S.C. 56, 60, and 1831o(d)(1) and
12 CFR part 3, subparts H and I, 12 CFR part 5.46,
12 CFR part 5, subpart E, and 12 CFR part 6
(national banks) and 12 U.S.C. 1467a(f) and
1467a(m)(B)(i)(III) and 12 CFR part 165 (Federal
savings associations); see also 12 CFR 225.8 (Board).
45 Calculations in this table are based on the
assumption that the countercyclical capital buffer
amount is zero.
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E. Countercyclical Capital Buffer
The proposed rule introduced a
countercyclical capital buffer applicable
to advanced approaches banking
organizations to augment the capital
conservation buffer during periods of
excessive credit growth. Under the
proposed rule, the countercyclical
capital buffer would have required
advanced approaches banking
organizations to hold additional
common equity tier 1 capital during
specific, agency-determined periods in
order to avoid limitations on
distributions and discretionary bonus
payments. The agencies and the FDIC
requested comment on the
countercyclical capital buffer and,
specifically, on any factors that should
be considered for purposes of
determining whether to activate it. One
commenter encouraged the agencies and
the FDIC to consider readily available
indicators of economic growth,
employment levels, and financial sector
profits. This commenter stated generally
that the agencies and the FDIC should
activate the countercyclical capital
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buffer during periods of general
economic growth or high financial
sector profits, instead of reserving it
only for periods of ‘‘excessive credit
growth.’’
Other commenters did not support
using the countercyclical capital buffer
as a macroeconomic tool. One
commenter encouraged the agencies and
the FDIC not to include the
countercyclical capital buffer in the
final rule and, instead, rely on the
Board’s longstanding authority over
monetary policy to mitigate excessive
credit growth and potential asset
bubbles. Another commenter questioned
the buffer’s effectiveness and
encouraged the agencies and the FDIC to
conduct a QIS prior to its
implementation. One commenter
recommended expanding the
applicability of the proposed
countercyclical capital buffer on a caseby-case basis to institutions with total
consolidated assets between $50 and
$250 billion. Another commenter,
however, supported the application of
the countercyclical capital buffer only to
institutions with total consolidated
assets above $250 billion.
The Dodd-Frank Act requires the
agencies to consider the use of
countercyclical aspects of capital
regulation, and the countercyclical
capital buffer is an explicitly
countercyclical element of capital
regulation.46 The agencies note that
implementation of the countercyclical
capital buffer for advanced approaches
banking organizations is an important
part of the Basel III framework, which
aims to enhance the resilience of the
banking system and reduce systemic
vulnerabilities. The agencies believe
that the countercyclical capital buffer is
most appropriately applied only to
advanced approaches banking
organizations because, generally, such
organizations are more interconnected
with other financial institutions.
Therefore, the marginal benefits to
financial stability from a countercyclical
capital buffer function should be greater
with respect to such institutions.
Application of the countercyclical
capital buffer only to advanced
approaches banking organizations also
reflects the fact that making cyclical
adjustments to capital requirements may
produce smaller financial stability
benefits and potentially higher marginal
costs for smaller banking organizations.
The countercyclical capital buffer is
designed to take into account the macro-
financial environment in which banking
organizations function and to protect
the banking system from the systemic
vulnerabilities that may build-up during
periods of excessive credit growth,
which may potentially unwind in a
disorderly way, causing disruptions to
financial institutions and ultimately
economic activity.
The countercyclical capital buffer
aims to protect the banking system and
reduce systemic vulnerabilities in two
ways. First, the accumulation of a
capital buffer during an expansionary
phase could increase the resilience of
the banking system to declines in asset
prices and consequent losses that may
occur when the credit conditions
weaken. Specifically, when the credit
cycle turns following a period of
excessive credit growth, accumulated
capital buffers act to absorb the abovenormal losses that a banking
organization likely would face.
Consequently, even after these losses are
realized, banking organizations would
remain healthy and able to access
funding, meet obligations, and continue
to serve as credit intermediaries.
Second, a countercyclical capital buffer
also may reduce systemic vulnerabilities
and protect the banking system by
mitigating excessive credit growth and
increases in asset prices that are not
supported by fundamental factors. By
increasing the amount of capital
required for further credit extensions, a
countercyclical capital buffer may limit
excessive credit.47 Thus, the agencies
believe that the countercyclical capital
buffer is an appropriate macroeconomic
tool and are including it in the final
rule. One commenter expressed concern
that the proposed rule would not
require the agencies and the FDIC to
activate the countercyclical capital
buffer pursuant to a joint, interagency
determination. This commenter
encouraged the agencies and the FDIC to
adopt an interagency process for
activating the buffer for purposes of the
final rule. As discussed in the Basel III
NPR, the agencies and the FDIC
anticipate making such determinations
jointly. Because the countercyclical
capital buffer amount would be linked
to the condition of the overall U.S.
financial system and not the
characteristics of an individual banking
organization, the agencies expect that
the countercyclical capital buffer
amount would be the same at the
depository institution and holding
company levels. The agencies and the
46 Section 616(a), (b), and (c) of the Dodd-Frank
Act, codified at 12 U.S.C. 1844(b), 1464a(g)(1), and
3907(a)(1).
.
47 The operation of the countercyclical capital
buffer is also consistent with sections 616(a), (b),
and (c) of the Dodd-Frank Act, codified at 12 U.S.C.
1844(b), 1464a(g)(1), and 3907(a)(1).
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FDIC solicited comment on the
appropriateness of the proposed 12month prior notification period for the
countercyclical capital buffer amount.
One commenter expressed concern
regarding the potential for the agencies
and the FDIC to activate the
countercyclical capital buffer without
providing banking organizations
sufficient notice, and specifically
requested the implementation of a prior
notification requirement of not less than
12 months for purposes of the final rule.
In general, to provide banking
organizations with sufficient time to
adjust to any changes to the
countercyclical capital buffer under the
final rule, the agencies and the FDIC
expect to announce an increase in the
U.S. countercyclical capital buffer
amount with an effective date at least 12
months after their announcement.
However, if the agencies and the FDIC
determine that a more immediate
implementation is necessary based on
economic conditions, the agencies may
require an earlier effective date. The
agencies and the FDIC will follow the
same procedures in adjusting the
countercyclical capital buffer applicable
for exposures located in foreign
jurisdictions.
For purposes of the final rule,
consistent with the proposal, a decrease
in the countercyclical capital buffer
amount will be effective on the day
following announcement of the final
determination or the earliest date
permissible under applicable law or
regulation, whichever is later. In
addition, the countercyclical capital
buffer amount will return to zero
percent 12 months after its effective
date, unless the agencies and the FDIC
announce a decision to maintain the
adjusted countercyclical capital buffer
amount or adjust it again before the
expiration of the 12-month period.
The countercyclical capital buffer
augments the capital conservation buffer
by up to 2.5 percent of a banking
organization’s total risk-weighted assets.
Consistent with the proposal, the final
rule requires an advanced approaches
banking organization to determine its
countercyclical capital buffer amount by
calculating the weighted average of the
countercyclical capital buffer amounts
established for the national jurisdictions
where the banking organization has
private sector credit exposures. The
contributing weight assigned to a
jurisdiction’s countercyclical capital
buffer amount is calculated by dividing
the total risk-weighted assets for the
banking organization’s private sector
credit exposures located in the
jurisdiction by the total risk-weighted
assets for all of the banking
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organization’s private sector credit
exposures.
Under the proposed rule, private
sector credit exposure was defined as an
exposure to a company or an individual
that is included in credit risk-weighted
assets, not including an exposure to a
sovereign entity, the Bank for
International Settlements, the European
Central Bank, the European
Commission, the International Monetary
Fund, a multilateral development bank
(MDB), a public sector entity (PSE), or
a Government-sponsored Enterprise
(GSE). While the proposed definition
excluded covered positions with
specific risk under the market risk rule,
the agencies and the FDIC explicitly
recognized that they should be included
in the measure of risk-weighted assets
for private-sector exposures and asked a
question regarding how to incorporate
these positions in the measure of riskweighted assets, particularly for
positions for which a banking
organization uses models to measure
specific risk. The agencies and the FDIC
did not receive comments on this
question.
The final rule includes covered
positions under the market risk rule in
the definition of private sector credit
exposure. Thus, a private sector credit
exposure is an exposure to a company
or an individual, not including an
exposure to a sovereign entity, the Bank
for International Settlements, the
European Central Bank, the European
Commission, the International Monetary
Fund, an MDB, a PSE, or a GSE. The
final rule is also more specific than the
proposal regarding how to calculate
risk-weighted assets for private sector
credit exposures, and harmonizes that
calculation with the advanced
approaches banking organization’s
determination of its capital conservation
buffer generally. An advanced
approaches banking organization is
subject to the countercyclical capital
buffer regardless of whether it has
completed the parallel run process and
received notification from its primary
Federal supervisor pursuant to section
121(d) of the rule. The methodology an
advanced approaches banking
organization must use for determining
risk-weighted assets for private sector
credit exposures must be the
methodology that the banking
organization uses to determine its riskbased capital ratios under section 10 of
the final rule. Notwithstanding this
provision, the risk-weighted asset
amount for a private sector credit
exposure that is a covered position is its
specific risk add-on, as determined
under the market risk rule’s
standardized measurement method for
specific risk, multiplied by 12.5. The
agencies chose this methodology
because it allows the specific risk of a
position to be allocated to the position’s
geographic location in a consistent
manner across banking organizations.
Consistent with the proposal, under
the final rule the geographic location of
a private sector credit exposure (that is
not a securitization exposure) is the
national jurisdiction where the borrower
is located (that is, where the borrower
is incorporated, chartered, or similarly
established or, if it is an individual,
where the borrower resides). If,
however, the decision to issue the
private sector credit exposure is based
primarily on the creditworthiness of a
protection provider, the location of the
62039
non-securitization exposure is the
location of the protection provider. The
location of a securitization exposure is
the location of the underlying
exposures, determined by reference to
the location of the borrowers on those
exposures. If the underlying exposures
are located in more than one national
jurisdiction, the location of a
securitization exposure is the national
jurisdiction where the underlying
exposures with the largest aggregate
unpaid principal balance are located.
Table 2 illustrates how an advanced
approaches banking organization
calculates its weighted average
countercyclical capital buffer amount.
In the following example, the
countercyclical capital buffer
established in the various jurisdictions
in which the banking organization has
private sector credit exposures is
reported in column A. Column B
contains the banking organization’s riskweighted asset amounts for the private
sector credit exposures in each
jurisdiction. Column C shows the
contributing weight for each
countercyclical capital buffer amount,
which is calculated by dividing each of
the rows in column B by the total for
column B. Column D shows the
contributing weight applied to each
countercyclical capital buffer amount,
calculated as the product of the
corresponding contributing weight
(column C) and the countercyclical
capital buffer set by each jurisdiction’s
national supervisor (column A). The
sum of the rows in column D shows the
banking organization’s weighted average
countercyclical capital buffer, which is
1.4 percent of risk-weighted assets.
TABLE 2—EXAMPLE OF WEIGHTED AVERAGE BUFFER CALCULATION FOR AN ADVANCED APPROACHES BANKING
ORGANIZATION
Countercyclical
capital buffer
amount set by
national supervisor (percent)
Banking
organization’s
risk-weighted
assets for
private sector
credit
exposures ($b)
Contributing
weight
(column B/
column B total)
Contributing
weight applied to
each
countercyclical
capital buffer
amount
(column A *
column C)
(A)
(B)
(C)
(D)
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Non-U.S. jurisdiction 1 .....................................................................
Non-U.S. jurisdiction 2 .....................................................................
U.S ...................................................................................................
2.0
1.5
1
250
100
500
0.29
0.12
0.59
0.6
0.2
0.6
Total ..........................................................................................
............................
850
1.00
1.4
The countercyclical capital buffer
expands a banking organization’s capital
conservation buffer range for purposes
of determining the banking
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organization’s maximum payout ratio.
For instance, if an advanced approaches
banking organization’s countercyclical
capital buffer amount is equal to zero
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percent of total risk-weighted assets, the
banking organization must maintain a
buffer of greater than 2.5 percent of total
risk-weighted assets to avoid restrictions
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on its distributions and discretionary
bonus payments. However, if its
countercyclical capital buffer amount is
equal to 2.5 percent of total riskweighted assets, the banking
organization must maintain a buffer of
greater than 5 percent of total riskweighted assets to avoid restrictions on
its distributions and discretionary bonus
payments.
As another example, if the advanced
approaches banking organization from
the example in Table 2 above has a
capital conservation buffer of 2.0
percent, and each of the jurisdictions in
which it has private sector credit
exposures sets its countercyclical
capital buffer amount equal to zero, the
banking organization would be subject
to a maximum payout ratio of 60
percent. If, instead, each country sets its
countercyclical capital buffer amount as
shown in Table 2, resulting in a
countercyclical capital buffer amount of
1.4 percent of total risk-weighted assets,
the banking organization’s capital
conservation buffer ranges would be
expanded as shown in Table 3 below.
As a result, the banking organization
would now be subject to a stricter 40
percent maximum payout ratio based on
its capital conservation buffer of 2.0
percent.
TABLE 3—CAPITAL CONSERVATION BUFFER AND MAXIMUM PAYOUT RATIO 48
Maximum payout ratio
(as a percentage of eligible retained
income)
Capital conservation buffer as expanded by the countercyclical capital buffer amount from Table 2
Greater than 3.9 percent (2.5 percent + 100 percent of the countercyclical capital buffer of 1.4) .........
Less than or equal to 3.9 percent, and greater than 2.925 percent (1.875 percent plus 75 percent of
the countercyclical capital buffer of 1.4).
Less than or equal to 2.925 percent, and greater than 1.95 percent (1.25 percent plus 50 percent of
the countercyclical capital buffer of 1.4).
Less than or equal to 1.95 percent, and greater than 0.975 percent (.625 percent plus 25 percent of
the countercyclical capital buffer of 1.4).
Less than or equal to 0.975 percent ........................................................................................................
The countercyclical capital buffer
amount under the final rule for U.S.
credit exposures is initially set to zero,
but it could increase if the agencies and
the FDIC determine that there is
excessive credit in the markets that
could lead to subsequent wide-spread
market failures. Generally, a zero
percent countercyclical capital buffer
amount will reflect an assessment that
economic and financial conditions are
consistent with a period of little or no
excessive ease in credit markets
associated with no material increase in
system-wide credit risk. A 2.5 percent
countercyclical capital buffer amount
will reflect an assessment that financial
markets are experiencing a period of
excessive ease in credit markets
associated with a material increase in
system-wide credit risk.
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F. Prompt Corrective Action
Requirements
All insured depository institutions,
regardless of total asset size or foreign
exposure, currently are required to
compute PCA capital levels using the
agencies’ and the FDIC’s general riskbased capital rules, as supplemented by
the market risk rule. Section 38 of the
Federal Deposit Insurance Act directs
the federal banking agencies and the
FDIC to resolve the problems of insured
depository institutions at the least cost
to the Deposit Insurance Fund.49 To
48 Calculations in this table are based on the
assumption that the countercyclical capital buffer
amount is 1.4 percent of risk-weighted assets, per
the example in Table 2.
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facilitate this purpose, the agencies and
the FDIC have established five
regulatory capital categories in the PCA
regulations that include capital
thresholds for the leverage ratio, tier 1
risk-based capital ratio, and the total
risk-based capital ratio for insured
depository institutions. These five PCA
categories under section 38 of the Act
and the PCA regulations are: ‘‘well
capitalized,’’ ‘‘adequately capitalized,’’
‘‘undercapitalized,’’ ‘‘significantly
undercapitalized,’’ and ‘‘critically
undercapitalized.’’ Insured depository
institutions that fail to meet these
capital measures are subject to
increasingly strict limits on their
activities, including their ability to
make capital distributions, pay
management fees, grow their balance
sheet, and take other actions.50 Insured
depository institutions are expected to
be closed within 90 days of becoming
‘‘critically undercapitalized,’’ unless
their primary Federal supervisor takes
such other action as that primary
Federal supervisor determines, with the
concurrence of the FDIC, would better
achieve the purpose of PCA.51
The proposal maintained the structure
of the PCA framework while increasing
some of the thresholds for the PCA
capital categories and adding the
proposed common equity tier 1 capital
ratio. For example, under the proposed
rule, the thresholds for adequately
49 12
U.S.C. 1831o.
U.S.C. 1831o(e)–(i). See 12 CFR part 6
(national banks) and 12 CFR part 165 (Federal
50 12
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No payout ratio limitation applies.
60 percent.
40 percent.
20 percent.
0 percent.
capitalized banking organizations would
be equal to the minimum capital
requirements. The risk-based capital
ratios for well capitalized banking
organizations under PCA would
continue to be two percentage points
higher than the ratios for adequatelycapitalized banking organizations, and
the leverage ratio for well capitalized
banking organizations under PCA would
be one percentage point higher than for
adequately-capitalized banking
organizations. Advanced approaches
banking organizations that are insured
depository institutions also would be
required to satisfy a supplementary
leverage ratio of 3 percent in order to be
considered adequately capitalized.
While the proposed PCA levels do not
incorporate the capital conservation
buffer, the PCA and capital conservation
buffer frameworks would complement
each other to ensure that banking
organizations hold an adequate amount
of common equity tier 1 capital.
The agencies and the FDIC received a
number of comments on the proposed
PCA framework. Several commenters
suggested modifications to the proposed
PCA levels, particularly with respect to
the leverage ratio. For example, a few
commenters encouraged the agencies
and the FDIC to increase the adequatelycapitalized and well capitalized
categories for the leverage ratio to six
percent or more and eight percent or
savings associations) (OCC); 12 CFR part 208,
subpart D (Board).
51 12 U.S.C. 1831o(g)(3).
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more, respectively. According to one
commenter, such thresholds would
more closely align with the actual
leverage ratios of many state-charted
depository institutions.
Another commenter expressed
concern regarding the operational
complexity of the proposed PCA
framework in view of the addition of the
common equity tier 1 capital ratio and
the interaction of the PCA framework
and the capital conservation buffer. For
example, under the proposed rule a
banking organization could be well
capitalized for PCA purposes and, at the
same time, be subject to restrictions on
dividends and bonus payments. Other
banking organizations expressed
concern that the proposed PCA levels
would adversely affect their ability to
lend and generate income. This,
according to a commenter, also would
reduce net income and return-on-equity.
The agencies believe the capital
conservation buffer complements the
PCA framework—the former works to
keep banking organizations above the
minimum capital ratios, whereas the
latter imposes increasingly stringent
consequences on depository
institutions, particularly as they fall
below the minimum capital ratios.
Because the capital conservation buffer
is designed to absorb losses in stressful
periods, the agencies believe it is
appropriate for a depository institution
to be able to use some of its capital
conservation buffer without being
considered less than well capitalized for
PCA purposes.
A few comments pertained
specifically to issues affecting BHCs and
SLHCs. A commenter encouraged the
Board to require an advanced
approaches banking organization,
including a BHC, to use the advanced
approaches rule for determining
whether it is well capitalized for PCA
purposes. This commenter maintained
that neither the Bank Holding Company
Act 52 nor section 171 of the Dodd-Frank
Act requires an advanced approaches
banking organization to use the lower of
its minimum ratios as calculated under
the general risk-based capital rules and
the advanced approaches rule to
determine well capitalized status.
Another commenter requested
clarification from the Board that section
171 of the Dodd-Frank Act does not
apply to determinations regarding
whether a BHC is a financial holding
company under Board regulations. In
order to elect to be a financial holding
company under the Bank Holding
Company Act, as amended by section
616 of the Dodd-Frank Act, a BHC and
all of its depository institution
subsidiaries must be well capitalized
and well managed. The final rule does
not establish the standards for
determining whether a BHC is ‘‘wellcapitalized.’’
Consistent with the proposal, the final
rule augments the PCA capital
categories by introducing a common
equity tier 1 capital measure for four of
the five PCA categories (excluding the
critically undercapitalized PCA
category).53 In addition, the final rule
revises the three current risk-based
capital measures for four of the five PCA
categories to reflect the final rule’s
changes to the minimum risk-based
capital ratios, as provided in the agencyspecific revisions to the agencies’ PCA
regulations. All banking organizations
that are insured depository institutions
will remain subject to leverage measure
thresholds using the current leverage
ratio in the form of tier 1 capital to
62041
average total consolidated assets. In
addition, the final rule amends the PCA
leverage measure for advanced
approaches depository institutions to
include the supplementary leverage
ratio that explicitly applies to the
‘‘adequately capitalized’’ and
‘‘undercapitalized’’ capital categories.
All insured depository institutions
must comply with the revised PCA
thresholds beginning on January 1,
2015. Consistent with transition
provisions in the proposed rules, the
supplementary leverage measure for
advanced approaches banking
organizations that are insured
depository institutions becomes
effective on January 1, 2018. Changes to
the definitions of the individual capital
components that are used to calculate
the relevant capital measures under
PCA are governed by the transition
arrangements discussed in section VIII.3
below. Thus, the changes to these
definitions, including any deductions
from or adjustments to regulatory
capital, automatically flow through to
the definitions in the PCA framework.
Table 4 sets forth the risk-based
capital and leverage ratio thresholds
under the final rule for each of the PCA
capital categories for all insured
depository institutions. For each PCA
category except critically
undercapitalized, an insured depository
institution must satisfy a minimum
common equity tier 1 capital ratio, in
addition to a minimum tier 1 risk-based
capital ratio, total risk-based capital
ratio, and leverage ratio. In addition to
the aforementioned requirements,
advanced approaches banking
organizations that are insured
depository institutions are also subject
to a supplementary leverage ratio.
TABLE 4—PCA LEVELS FOR ALL INSURED DEPOSITORY INSTITUTIONS
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PCA category
Total riskbased capital
(RBC) measure (total RBC
ratio—
(percent))
Leverage measure
Leverage ratio
(percent)
Supplementary
leverage ratio
(percent) *
PCA requirements
≥10
≥8
≥8
≥6
≥6.5
≥4.5
≥5
≥4
Not applicable
≥3.0
Unchanged from current rule *
*
<8
<6
Well capitalized ....
Adequately-capitalized.
Undercapitalized ..
Significantly
undercapitalized.
Critically undercapitalized.
Common
equity tier 1
RBC measure
(common
equity tier 1
RBC ratio
(percent))
Tier 1 RBC
measure (tier
1 RBC ratio
(percent))
<6
<4
<4.5
<3
<4
<3
<3.00
Not applicable
*
*
Not applicable
*
Tangible equity (defined as tier 1 capital plus non-tier 1 perpetual
preferred stock) to total assets ≤2
* The supplementary leverage ratio as a PCA requirement applies only to advanced approaches banking organizations that are insured depository institutions. The supplementary leverage ratio also applies to advanced approaches bank holding companies, although not in the form of
a PCA requirement.
52 12
U.S.C. 1841, et seq.
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To be well capitalized for purposes of
the final rule, an insured depository
institution must maintain a total riskbased capital ratio of 10 percent or
more; a tier 1 capital ratio of 8 percent
or more; a common equity tier 1 capital
ratio of 6.5 percent or more; and a
leverage ratio of 5 percent or more. An
adequately-capitalized depository
institution must maintain a total riskbased capital ratio of 8 percent or more;
a tier 1 capital ratio of 6 percent or
more; a common equity tier 1 capital
ratio of 4.5 percent or more; and a
leverage ratio of 4 percent or more.
An insured depository institution is
undercapitalized under the final rule if
its total capital ratio is less than 8
percent, if its tier 1 capital ratio is less
than 6 percent, its common equity tier
1 capital ratio is less than 4.5 percent,
or its leverage ratio is less than 4
percent. If an institution’s tier 1 capital
ratio is less than 4 percent, or its
common equity tier 1 capital ratio is less
than 3 percent, it would be considered
significantly undercapitalized. The
other numerical capital ratio thresholds
for being significantly undercapitalized
remain unchanged from the current
rules.54
The determination of whether an
insured depository institution is
critically undercapitalized for PCA
purposes is based on its ratio of tangible
equity to total assets.55 This is a
statutory requirement within the PCA
framework, and the experience of the
recent financial crisis has confirmed
that tangible equity is of critical
importance in assessing the viability of
an insured depository institution.
Tangible equity for PCA purposes is
currently defined as including core
capital elements,56 which consist of: (1)
Common stockholder’s equity, (2)
qualifying noncumulative perpetual
preferred stock (including related
surplus), and (3) minority interest in the
54 Under current PCA standards, in order to
qualify as well-capitalized, an insured depository
institution must not be subject to any written
agreement, order, capital directive, or prompt
corrective action directive issued by its primary
Federal regulator pursuant to section 8 of the
Federal Deposit Insurance Act, the International
Lending Supervision Act of 1983, or section 38 of
the Federal Deposit Insurance Act, or any regulation
thereunder. See 12 CFR 6.4(b)(1)(iv) (national
banks), 12 CFR 165.4(b)(1)(iv) (Federal savings
associations) (OCC); 12 CFR 208.43(b)(1)(iv)
(Board). The final rule does not change this
requirement.
55 See 12 U.S.C. 1831o(c)(3)(A) and (B), which for
purposes of the ‘‘critically undercapitalized’’ PCA
category requires the ratio of tangible equity to total
assets to be set at an amount ‘‘not less than 2
percent of total assets.’’
56 The OCC notes that under the OCC’s PCA rule
with respect to national banks, the definition of
tangible equity does not use the term ‘‘core capital
elements.’’ 12 CFR 6.2(g).
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equity accounts of consolidated
subsidiaries; plus outstanding
cumulative preferred perpetual stock;
minus all intangible assets except
mortgage servicing rights to the extent
permitted in tier 1 capital. The current
PCA definition of tangible equity does
not address the treatment of DTAs in
determining whether an insured
depository institution is critically
undercapitalized.
Consistent with the proposal, the final
rule revises the calculation of the capital
measure for the critically
undercapitalized PCA category by
revising the definition of tangible equity
to consist of tier 1 capital, plus
outstanding perpetual preferred stock
(including related surplus) not included
in tier 1 capital. The revised definition
more appropriately aligns the
calculation of tangible equity with the
calculation of tier 1 capital generally for
regulatory capital requirements. Assets
included in a banking organization’s
equity under GAAP, such as DTAs, are
included in tangible equity only to the
extent that they are included in tier 1
capital. The agencies believe this
modification promotes consistency and
provides for clearer boundaries across
and between the various PCA categories.
In addition to the changes described
in this section, the OCC proposed to
integrate its PCA rules for national
banks and Federal savings associations.
Specifically, the OCC proposed to make
12 CFR part 6 applicable to Federal
savings associations, and to rescind the
current PCA rules in 12 CFR part 165
governing Federal savings associations,
with the exception of § 165.8
(Procedures for reclassifying a federal
savings association based on criteria
other than capital), and § 165.9 (Order to
dismiss a director or senior executive
officer). The OCC proposed to retain
§§ 165.8 and 165.9 because those
sections relate to enforcement
procedures and the procedural rules in
12 CFR part 19 do not apply to Federal
savings associations at this time.
Therefore, the OCC must retain §§ 165.8
and 165.9. Finally, the proposal also
made non-substantive, technical
amendments to part 6 and §§ 165.8 and
165.9.
The OCC received no comments on
these proposed changes and therefore is
adopting these proposed amendments as
final, with minor technical edits. The
OCC notes that, consistent with the
proposal, as part of the integration of
Federal savings associations, Federal
savings associations will now calculate
tangible equity based on average total
assets rather than period-end total
assets.
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G. Supervisory Assessment of Overall
Capital Adequacy
Capital helps to ensure that
individual banking organizations can
continue to serve as credit
intermediaries even during times of
stress, thereby promoting the safety and
soundness of the overall U.S. banking
system. The agencies’ general risk-based
capital rules indicate that the capital
requirements are minimum standards
generally based on broad credit-risk
considerations.57 The risk-based capital
ratios under these rules do not explicitly
take account of the quality of individual
asset portfolios or the range of other
types of risk to which banking
organizations may be exposed, such as
interest-rate, liquidity, market, or
operational risks.58
A banking organization is generally
expected to have internal processes for
assessing capital adequacy that reflect a
full understanding of its risks and to
ensure that it holds capital
corresponding to those risks to maintain
overall capital adequacy.59 The nature
of such capital adequacy assessments
should be commensurate with banking
organizations’ size, complexity, and
risk-profile. Consistent with
longstanding practice, supervisory
assessment of capital adequacy will take
account of whether a banking
organization plans appropriately to
maintain an adequate level of capital
given its activities and risk profile, as
well as risks and other factors that can
affect a banking organization’s financial
condition, including, for example, the
level and severity of problem assets and
its exposure to operational and interest
rate risk, and significant asset
concentrations. For this reason, a
supervisory assessment of capital
adequacy may differ significantly from
conclusions that might be drawn solely
from the level of a banking
organization’s regulatory capital ratios.
In light of these considerations, as a
prudential matter, a banking
organization is generally expected to
operate with capital positions well
57 See 12 CFR part 3, App. A, Sec. 1(b)(1)
(national banks) and 12 CFR part 167.3(b) and (c)
(Federal savings associations) (OCC); 12 CFR 208.4
(state member banks).
58 The risk-based capital ratios of a banking
organization subject to the market risk rule do
include capital requirements for the market risk of
covered positions, and the risk-based capital ratios
calculated using advanced approaches total riskweighted assets for an advanced approaches
banking organization that has completed the
parallel run process and received notification from
its primary Federal supervisor pursuant to section
121(d) do include a capital requirement for
operational risks.
59 The Basel framework incorporates similar
requirements under Pillar 2 of Basel II.
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above the minimum risk-based ratios
and to hold capital commensurate with
the level and nature of the risks to
which it is exposed, which may entail
holding capital significantly above the
minimum requirements. For example,
banking organizations contemplating
significant expansion proposals are
expected to maintain strong capital
levels substantially above the minimum
ratios and should not allow significant
diminution of financial strength below
these strong levels to fund their
expansion plans. Banking organizations
with high levels of risk are also
expected to operate even further above
minimum standards. In addition to
evaluating the appropriateness of a
banking organization’s capital level
given its overall risk profile, the
supervisory assessment takes into
account the quality and trends in a
banking organization’s capital
composition, including the share of
common and non-common-equity
capital elements.
Some commenters stated that they
manage their capital so that they operate
with a buffer over the minimum and
that examiners expect such a buffer.
These commenters expressed concern
that examiners will expect even higher
capital levels, such as a buffer in
addition to the new higher minimums
and capital conservation buffer (and
countercyclical capital buffer, if
applicable). Consistent with the
longstanding approach employed by the
agencies in their supervision of banking
organizations, section 10(d) of the final
rule maintains and reinforces
supervisory expectations by requiring
that a banking organization maintain
capital commensurate with the level
and nature of all risks to which it is
exposed and that a banking organization
have a process for assessing its overall
capital adequacy in relation to its risk
profile, as well as a comprehensive
strategy for maintaining an appropriate
level of capital.
The supervisory evaluation of a
banking organization’s capital adequacy,
including compliance with section
10(d), may include such factors as
whether the banking organization is
newly chartered, entering new
activities, or introducing new products.
The assessment also would consider
whether a banking organization is
receiving special supervisory attention,
has or is expected to have losses
resulting in capital inadequacy, has
significant exposure due to risks from
concentrations in credit or
nontraditional activities, or has
significant exposure to interest rate risk,
operational risk, or could be adversely
affected by the activities or condition of
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a banking organization’s holding
company or other affiliates.
Supervisors also evaluate the
comprehensiveness and effectiveness of
a banking organization’s capital
planning in light of its activities and
capital levels. An effective capital
planning process involves an
assessment of the risks to which a
banking organization is exposed and its
processes for managing and mitigating
those risks, an evaluation of its capital
adequacy relative to its risks, and
consideration of the potential impact on
its earnings and capital base from
current and prospective economic
conditions.60 While the elements of
supervisory review of capital adequacy
would be similar across banking
organizations, evaluation of the level of
sophistication of an individual banking
organization’s capital adequacy process
would be commensurate with the
banking organization’s size,
sophistication, and risk profile, similar
to the current supervisory practice.
H. Tangible Capital Requirement for
Federal Savings Associations
As part of the OCC’s overall effort to
integrate the regulatory requirements for
national banks and Federal savings
associations, the OCC proposed to
include a tangible capital requirement
for Federal savings associations.61
Under section 5(t)(2)(B) of HOLA,62
Federal savings associations are
required to maintain tangible capital in
an amount not less than 1.5 percent of
total assets.63 This statutory
60 See, e.g., SR 09–4, Applying Supervisory
Guidance and Regulations on the Payment of
Dividends, Stock Redemptions, and Stock
Repurchases at Bank Holding Companies (Board);
see also OCC Bulletin 2012–16, Guidance for
Evaluating Capital Planning and Adequacy.
61 Under Title III of the Dodd-Frank Act, the OCC
assumed all functions of the Office of Thrift
Supervision (OTS) and the Director of the OTS
relating to Federal savings associations. As a result,
the OCC has responsibility for the ongoing
supervision, examination and regulation of Federal
savings associations as of the transfer date of July
21, 2011. The Act also transfers to the OCC the
rulemaking authority of the OTS relating to all
savings associations, both state and Federal for
certain rules. Section 312(b)(2)(B)(i) (codified at 12
U.S.C. 5412(b)(2)(B)(i)). The FDIC has rulemaking
authority for the capital and PCA rules pursuant to
section 38 of the FDI Act (12 U.S.C. 1831n) and
section 5(t)(1)(A) of the Home Owners’ Loan Act (12
U.S.C.1464(t)(1)(A)).
62 12 U.S.C. 1464(t).
63 ‘‘Tangible capital’’ is defined in section
5(t)(9)(B) of HOLA to mean ‘‘core capital minus any
intangible assets (as intangible assets are defined by
the Comptroller of the Currency for national
banks.)’’ 12 U.S.C. 1464(t)(9)(B). Section 5(t)(9)(A)
of HOLA defines ‘‘core capital’’ to mean ‘‘core
capital as defined by the Comptroller of the
Currency for national banks, less any unidentifiable
intangible assets [goodwill]’’ unless the OCC
prescribes a more stringent definition. 12 U.S.C.
1464(t)(9)(A).
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requirement is implemented in the
OCC’s current capital rules applicable to
Federal savings associations at 12 CFR
167.9.64 Under that rule, tangible capital
is defined differently from other capital
measures, such as tangible equity in
current 12 CFR part 165.
After reviewing HOLA, the OCC
determined that a unique regulatory
definition of tangible capital is not
necessary to satisfy the requirement of
the statute. Therefore, the OCC is
defining ‘‘tangible capital’’ as the
amount of tier 1 capital plus the amount
of outstanding perpetual preferred stock
(including related surplus) not included
in tier 1 capital. This definition mirrors
the proposed definition of ‘‘tangible
equity’’ for PCA purposes.65 While the
OCC recognizes that the terms used are
not identical (‘‘capital’’ as compared to
‘‘equity’’), the OCC believes that this
revised definition of tangible capital
will reduce the computational burden
on Federal savings associations in
complying with this statutory mandate,
as well as remaining consistent with
both the purposes of HOLA and PCA.
The final rule adopts this definition as
proposed. In addition, in § 3.10(b)(5)
and (c)(5) of the proposal, the OCC
defined the term ‘‘Federal savings
association tangible capital ratio’’ to
mean the ratio of the Federal savings
association’s core capital (Tier 1 capital)
to total adjusted assets as calculated
under subpart B of part 3. The OCC
notes that this definition is inconsistent
with the proposed definition of the
tangible equity ratio for national banks
and Federal savings associations, at
§ 6.4(b)(5) and (c)(5), in which the
denominator of the ratio is quarterly
average total assets. Accordingly, in
keeping with the OCC’s goal of
integrating rules for Federal savings
associations and national banks
wherever possible and reducing
implementation burden associated with
a separate measure of tangible capital,
the final rule replaces the term ‘‘total
adjusted assets’’ in the definition of
‘‘Federal savings association tangible
capital ratio’’ with the term ‘‘average
total assets.’’ As a result of the changes
in these definitions, Federal savings
associations will no longer calculate the
tangible capital ratio using period end
total assets.
64 54
FR 49649 (Nov. 30, 1989).
12 CFR 6.2.
65 See
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V. Definition of Capital
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A. Capital Components and Eligibility
Criteria for Regulatory Capital
Instruments
1. Common Equity Tier 1 Capital
Under the proposed rule, common
equity tier 1 capital was defined as the
sum of a banking organization’s
outstanding common equity tier 1
capital instruments that satisfy the
criteria set forth in section 20(b) of the
proposal, related surplus (net of treasury
stock), retained earnings, AOCI, and
common equity tier 1 minority interest
subject to certain limitations, minus
regulatory adjustments and deductions.
The proposed rule set forth a list of
criteria that an instrument would be
required to meet to be included in
common equity tier 1 capital. The
proposed criteria were designed to
ensure that common equity tier 1 capital
instruments do not possess features that
would cause a banking organization’s
condition to further weaken during
periods of economic and market stress.
In the proposals, the agencies and the
FDIC indicated that they believe most
existing common stock instruments
issued by U.S. banking organizations
already would satisfy the proposed
criteria.
The proposed criteria also applied to
instruments issued by banking
organizations such as mutual banking
organizations where ownership of the
organization is not freely transferable or
evidenced by certificates of ownership
or stock. For these entities, the proposal
provided that instruments issued by
such organizations would be considered
common equity tier 1 capital if they are
fully equivalent to common stock
instruments in terms of their
subordination and availability to absorb
losses, and do not possess features that
could cause the condition of the
organization to weaken as a going
concern during periods of market stress.
The agencies and the FDIC noted in
the proposal that stockholders’ voting
rights generally are a valuable corporate
governance tool that permits parties
with an economic interest to participate
in the decision-making process through
votes on establishing corporate
objectives and policy, and in electing
the banking organization’s board of
directors. Therefore, the agencies
believe that voting common
stockholders’ equity (net of the
adjustments to and deductions from
common equity tier 1 capital proposed
under the rule) should be the dominant
element within common equity tier 1
capital. The proposal also provided that
to the extent that a banking organization
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issues non-voting common stock or
common stock with limited voting
rights, the underlying stock must be
identical to those underlying the
banking organization’s voting common
stock in all respects except for any
limitations on voting rights.
To ensure that a banking
organization’s common equity tier 1
capital would be available to absorb
losses as they occur, the proposed rule
would have required common equity
tier 1 capital instruments issued by a
banking organization to satisfy the
following criteria:
(1) The instrument is paid-in, issued
directly by the banking organization,
and represents the most subordinated
claim in a receivership, insolvency,
liquidation, or similar proceeding of the
banking organization.
(2) The holder of the instrument is
entitled to a claim on the residual assets
of the banking organization that is
proportional with the holder’s share of
the banking organization’s issued
capital after all senior claims have been
satisfied in a receivership, insolvency,
liquidation, or similar proceeding. That
is, the holder has an unlimited and
variable claim, not a fixed or capped
claim.
(3) The instrument has no maturity
date, can only be redeemed via
discretionary repurchases with the prior
approval of the banking organization’s
primary Federal supervisor, and does
not contain any term or feature that
creates an incentive to redeem.
(4) The banking organization did not
create at issuance of the instrument,
through any action or communication,
an expectation that it will buy back,
cancel, or redeem the instrument, and
the instrument does not include any
term or feature that might give rise to
such an expectation.
(5) Any cash dividend payments on
the instrument are paid out of the
banking organization’s net income and
retained earnings and are not subject to
a limit imposed by the contractual terms
governing the instrument.
(6) The banking organization has full
discretion at all times to refrain from
paying any dividends and making any
other capital distributions on the
instrument without triggering an event
of default, a requirement to make a
payment-in-kind, or an imposition of
any other restrictions on the banking
organization.
(7) Dividend payments and any other
capital distributions on the instrument
may be paid only after all legal and
contractual obligations of the banking
organization have been satisfied,
including payments due on more senior
claims.
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(8) The holders of the instrument bear
losses as they occur equally,
proportionately, and simultaneously
with the holders of all other common
stock instruments before any losses are
borne by holders of claims on the
banking organization with greater
priority in a receivership, insolvency,
liquidation, or similar proceeding.
(9) The paid-in amount is classified as
equity under GAAP.
(10) The banking organization, or an
entity that the banking organization
controls, did not purchase or directly or
indirectly fund the purchase of the
instrument.
(11) The instrument is not secured,
not covered by a guarantee of the
banking organization or of an affiliate of
the banking organization, and is not
subject to any other arrangement that
legally or economically enhances the
seniority of the instrument.
(12) The instrument has been issued
in accordance with applicable laws and
regulations. In most cases, the agencies
understand that the issuance of these
instruments would require the approval
of the board of directors of the banking
organization or, where applicable, of the
banking organization’s shareholders or
of other persons duly authorized by the
banking organization’s shareholders.
(13) The instrument is reported on the
banking organization’s regulatory
financial statements separately from
other capital instruments.
The agencies and the FDIC requested
comment on the proposed criteria for
inclusion in common equity tier 1, and
specifically on whether any of the
criteria would be problematic, given the
main characteristics of existing
outstanding common stock instruments.
A substantial number of comments
addressed the criteria for common
equity tier 1 capital. Generally,
commenters stated that the proposed
criteria could prevent some instruments
currently included in tier 1 capital from
being included in the new common
equity tier 1 capital measure.
Commenters stated that this could
create complicated and unnecessary
burden for banking organizations that
either would have to raise capital to
meet the common equity tier 1 capital
requirement or shrink their balance
sheets by selling off or winding down
assets and exposures. Many commenters
stated that the burden of raising new
capital would have the effect of
reducing lending overall, and that it
would be especially acute for smaller
banking organizations that have limited
access to capital markets.
Many commenters asked the agencies
and the FDIC to clarify several aspects
of the proposed criteria. For instance, a
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few commenters asked the agencies and
the FDIC to clarify the proposed
requirement that a common equity tier
1 capital instrument be redeemed only
with prior approval by a banking
organization’s primary Federal
supervisor. These commenters asked if
this criterion would require a banking
organization to note this restriction on
the face of a regulatory capital
instrument that it may be redeemed
only with the prior approval of the
banking organization’s primary Federal
supervisor.
The agencies note that the
requirement that common equity tier 1
capital instruments be redeemed only
with prior agency approval is consistent
with the agencies’ rules and federal law,
which generally provide that a banking
organization may not reduce its capital
by redeeming capital instruments
without receiving prior approval from
its primary Federal supervisor.66 The
final rule does not obligate the banking
organization to include this restriction
explicitly in the common equity tier 1
capital instrument’s documentation.
However, regardless of whether the
instrument documentation states that its
redemption is subject to agency
approval, the banking organization must
receive prior approval before redeeming
such instruments. The agencies believe
that the approval requirement is
appropriate as it provides for the
monitoring of the strength of a banking
organization’s capital position, and
therefore, have retained the proposed
requirement in the final rule.
Several commenters also expressed
concern about the proposed requirement
that dividend payments and any other
distributions on a common equity tier 1
capital instrument may be paid only
after all legal and contractual
obligations of the banking organization
have been satisfied, including payments
due on more senior claims. Commenters
stated that, as proposed, this
requirement could be construed to
prevent a banking organization from
paying a dividend on a common equity
tier 1 capital instrument because of
obligations that have not yet become
due or because of immaterial delays in
paying trade creditors 67 for obligations
incurred in the ordinary course of
business.
66 See 12 CFR 5.46 (national banks) and 12 CFR
part 163, subpart E (Federal savings associations)
(OCC); 12 CFR parts 208 and 225, appendix A,
section II(iii) (Board).
67 Trade creditors, for this purpose, would
include counterparties with whom the banking
organization contracts to procure office space and/
or supplies as well as basic services, such as
building maintenance.
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The agencies note that this criterion
should not prevent a banking
organization from paying a dividend on
a common equity tier 1 capital
instrument where it has incurred
operational obligations in the normal
course of business that are not yet due
or that are subject to minor delays for
reasons unrelated to the financial
condition of the banking organization,
such as delays related to contractual or
other legal disputes.
A number of commenters also
suggested that the proposed criteria
providing that dividend payments may
be paid only out of current and retained
earnings potentially could conflict with
state corporate law, including Delaware
state law. According to these
commenters, Delaware state law permits
a corporation to make dividend
payments out of its capital surplus
account, even when the organization
does not have current or retained
earnings.
The agencies observe that requiring
that dividends be paid only out of net
income and retained earnings is
consistent with federal law and the
existing regulations applicable to
insured depository institutions. Under
applicable statutes and regulations, a
national bank or federal savings
association may not declare and pay
dividends in any year in an amount that
exceeds the sum of its total net income
for that year plus its retained net income
for the preceding two years (minus
certain transfers), unless it receives
prior approval from the OCC. Therefore,
as applied to national banks and Federal
savings associations, this aspect of the
proposal did not include any
substantive changes from the general
risk-based capital rules.68 Accordingly,
with respect to national banks and
savings associations, the criterion does
not include surplus.
However, because this criterion
applies to the terms of the capital
instrument, which is governed by state
law, the Board is broadening the
criterion in the final rule to include
surplus for state-chartered companies
under its supervision that are subject to
the final rule. However, regardless of
provisions of state law, under the
Federal Reserve Act, state member
banks are subject to the same
restrictions as national banks that relate
to the withdrawal or impairment of their
capital stock, and the Board’s
regulations for state member banks
reflect these limitations on dividend
68 See 12 U.S.C. 60(b) and 12 CFR 5.63 and 5.64
(national banks) and 12 CFR 163.143 (Federal
savings associations) (OCC).
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62045
payments.69 It should be noted that
restrictions may be applied to BHC
dividends under the Board’s capital
plan rule for companies subject to that
rule.70
Finally, several commenters
expressed concerns about the potential
impact of the proposed criteria on stock
issued as part of certain employee stock
ownership plans (ESOPs) (as defined
under Employee Retirement Income
Security Act of 1974 71 (ERISA)
regulations at 29 CFR 2550.407d–6).
Under the proposed rule, an instrument
would not be included in common
equity tier 1 capital if the banking
organization creates an expectation that
it will buy back, cancel, or redeem the
instrument, or if the instrument
includes any term or feature that might
give rise to such an expectation.
Additionally, the criteria would prevent
a banking organization from including
in common equity tier 1 capital any
instrument that is subject to any type of
arrangement that legally or
economically enhances the seniority of
the instrument. Commenters noted that
under ERISA, stock that is not publicly
traded and issued as part of an ESOP
must include a ‘‘put option’’ that
requires the company to repurchase the
stock. By exercising the put option, an
employee can redeem the stock
instrument upon termination of
employment. Commenters noted that
this put option clearly creates an
expectation that the instrument will be
redeemed and arguably enhances the
seniority of the instrument. Therefore,
the commenters stated that the put
option could prevent a privately-held
banking organization from including
earned ESOP shares in its common
equity tier 1 capital.
The agencies do not believe that an
ERISA-mandated put option should
prohibit ESOP shares from being
included in common equity tier 1
capital. Therefore, under the final rule,
shares issued under an ESOP by a
banking organization that is not
publicly-traded are exempt from the
criteria that the shares can be redeemed
only via discretionary repurchases and
are not subject to any other arrangement
that legally or economically enhances
their seniority, and that the banking
organization not create an expectation
that the shares will be redeemed. In
addition to the concerns described
above, because stock held in an ESOP is
awarded by a banking organization for
the retirement benefit of its employees,
some commenters expressed concern
69 12
CFR 208.5.
12 CFR 225.8.
71 29 U.S.C. 1002, et seq.
70 See
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that such stock may not conform to the
criterion prohibiting a banking
organization from directly or indirectly
funding a capital instrument. Because
the agencies believe that a banking
organization should have the flexibility
to provide an ESOP as a benefit for its
employees, the final rule provides that
ESOP stock does not violate such
criterion. Under the final rule, a banking
organization’s common stock held in
trust for the benefit of employees as part
of an ESOP in accordance with both
ERISA and ERISA-related U.S. tax code
requirements will qualify for inclusion
as common equity tier 1 capital only to
the extent that the instrument is
includable as equity under GAAP and
that it meets all other criteria of section
20(b)(1) of the final rule. Stock
instruments held by an ESOP that are
unawarded or unearned by employees
or reported as ‘‘temporary equity’’ under
GAAP (in the case of U.S. Securities and
Exchange Commission (SEC)
registrants), may not be counted as
equity under GAAP and therefore may
not be included in common equity tier
1 capital.
After reviewing the comments
received, the agencies have decided to
finalize the proposed criteria for
common equity tier 1 capital
instruments, modified as discussed
above. Although it is possible some
currently outstanding common equity
instruments may not meet the common
equity tier 1 capital criteria, the agencies
believe that most common equity
instruments that are currently eligible
for inclusion in banking organizations’
tier 1 capital meet the common equity
tier 1 capital criteria, and have not
received information that would
support a different conclusion. The
agencies therefore believe that most
banking organizations will not be
required to reissue common equity
instruments in order to comply with the
final common equity tier 1 capital
criteria. The final revised criteria for
inclusion in common equity tier 1
capital are set forth in section 20(b)(1)
of the final rule.
2. Additional Tier 1 Capital
Consistent with Basel III, the agencies
and the FDIC proposed that additional
tier 1 capital would equal the sum of:
Additional tier 1 capital instruments
that satisfy the criteria set forth in
section 20(c) of the proposal, related
surplus, and any tier 1 minority interest
that is not included in a banking
organization’s common equity tier 1
capital (subject to the proposed
limitations on minority interest), less
applicable regulatory adjustments and
deductions. The agencies and the FDIC
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proposed the following criteria for
additional tier 1 capital instruments in
section 20(c):
(1) The instrument is issued and paidin.
(2) The instrument is subordinated to
depositors, general creditors, and
subordinated debt holders of the
banking organization in a receivership,
insolvency, liquidation, or similar
proceeding.
(3) The instrument is not secured, not
covered by a guarantee of the banking
organization or of an affiliate of the
banking organization, and not subject to
any other arrangement that legally or
economically enhances the seniority of
the instrument.
(4) The instrument has no maturity
date and does not contain a dividend
step-up or any other term or feature that
creates an incentive to redeem.
(5) If callable by its terms, the
instrument may be called by the
banking organization only after a
minimum of five years following
issuance, except that the terms of the
instrument may allow it to be called
earlier than five years upon the
occurrence of a regulatory event (as
defined in the agreement governing the
instrument) that precludes the
instrument from being included in
additional tier 1 capital or a tax event.
In addition:
(i) The banking organization must
receive prior approval from its primary
Federal supervisor to exercise a call
option on the instrument.
(ii) The banking organization does not
create at issuance of the instrument,
through any action or communication,
an expectation that the call option will
be exercised.
(iii) Prior to exercising the call option,
or immediately thereafter, the banking
organization must either:
(A) Replace the instrument to be
called with an equal amount of
instruments that meet the criteria under
section 20(b) or (c) of the proposed rule
(replacement can be concurrent with
redemption of existing additional tier 1
capital instruments); or
(B) Demonstrate to the satisfaction of
its primary Federal supervisor that
following redemption, the banking
organization will continue to hold
capital commensurate with its risk.
(6) Redemption or repurchase of the
instrument requires prior approval from
the banking organization’s primary
Federal supervisor.
(7) The banking organization has full
discretion at all times to cancel
dividends or other capital distributions
on the instrument without triggering an
event of default, a requirement to make
a payment-in-kind, or an imposition of
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other restrictions on the banking
organization except in relation to any
capital distributions to holders of
common stock.
(8) Any capital distributions on the
instrument are paid out of the banking
organization’s net income and retained
earnings.
(9) The instrument does not have a
credit-sensitive feature, such as a
dividend rate that is reset periodically
based in whole or in part on the banking
organization’s credit quality, but may
have a dividend rate that is adjusted
periodically independent of the banking
organization’s credit quality, in relation
to general market interest rates or
similar adjustments.
(10) The paid-in amount is classified
as equity under GAAP.
(11) The banking organization, or an
entity that the banking organization
controls, did not purchase or directly or
indirectly fund the purchase of the
instrument.
(12) The instrument does not have
any features that would limit or
discourage additional issuance of
capital by the banking organization,
such as provisions that require the
banking organization to compensate
holders of the instrument if a new
instrument is issued at a lower price
during a specified time frame.
(13) If the instrument is not issued
directly by the banking organization or
by a subsidiary of the banking
organization that is an operating entity,
the only asset of the issuing entity is its
investment in the capital of the banking
organization, and proceeds must be
immediately available without
limitation to the banking organization or
to the banking organization’s top-tier
holding company in a form which meets
or exceeds all of the other criteria for
additional tier 1 capital instruments.72
(14) For an advanced approaches
banking organization, the governing
agreement, offering circular, or
prospectus of an instrument issued after
January 1, 2013, must disclose that the
holders of the instrument may be fully
subordinated to interests held by the
U.S. government in the event that the
banking organization enters into a
receivership, insolvency, liquidation, or
similar proceeding.
The proposed criteria were designed
to ensure that additional tier 1 capital
instruments would be available to
absorb losses on a going-concern basis.
TruPS and cumulative perpetual
preferred securities, which are eligible
for limited inclusion in tier 1 capital
72 De minimis assets related to the operation of
the issuing entity could be disregarded for purposes
of this criterion.
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under the general risk-based capital
rules for bank holding companies,
generally would not qualify for
inclusion in additional tier 1 capital.73
As explained in the proposal, the
agencies believe that instruments that
allow for the accumulation of interest
payable, like cumulative preferred
securities, are not likely to absorb losses
to the degree appropriate for inclusion
in tier 1 capital. In addition, the
exclusion of these instruments from the
tier 1 capital of depository institution
holding companies would be consistent
with section 171 of the Dodd-Frank Act.
The agencies noted in the proposal
that under Basel III, instruments
classified as liabilities for accounting
purposes could potentially be included
in additional tier 1 capital. However, the
agencies and the FDIC proposed that an
instrument classified as a liability under
GAAP could not qualify as additional
tier 1 capital, reflecting the agencies’
and the FDIC’s view that allowing only
instruments classified as equity under
GAAP in tier 1 capital helps strengthen
the loss-absorption capabilities of
additional tier 1 capital instruments,
thereby increasing the quality of the
capital base of U.S. banking
organizations.
The agencies and the FDIC also
proposed to allow banking organizations
to include in additional tier 1 capital
instruments that were: (1) Issued under
the Small Business Jobs Act of 2010 74
or, prior to October 4, 2010, under the
Emergency Economic Stabilization Act
of 2008,75 and (2) included in tier 1
capital under the agencies’ and the
FDIC’s general risk-based capital rules.
Under the proposal, these instruments
would be included in tier 1 capital
regardless of whether they satisfied the
proposed qualifying criteria for common
equity tier 1 or additional tier 1 capital.
The agencies and the FDIC explained in
the proposal that continuing to permit
these instruments to be included in tier
1 capital is important to promote
financial recovery and stability
following the recent financial crisis.76
A number of commenters addressed
the proposed criteria for additional tier
1 capital. Consistent with comments on
the criteria for common equity tier 1
capital, commenters generally argued
that imposing new restrictions on
qualifying regulatory capital
instruments would be burdensome for
many banking organizations that would
73 See 12 CFR part 225, appendix A, section
II.A.1.
74 Public Law 111–240, 124 Stat. 2504 (2010).
75 Public Law 110–343, 122 Stat. 3765 (October 3,
2008).
76 See, e.g., 73 FR 43982 (July 29, 2008); see also
76 FR 35959 (June 21, 2011).
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be required to raise additional capital or
to shrink their balance sheets to phase
out existing regulatory capital
instruments that no longer qualify as
regulatory capital under the proposed
rule.
With respect to the proposed criteria,
commenters requested that the agencies
and the FDIC make a number of changes
and clarifications. Specifically,
commenters asked the agencies and the
FDIC to clarify the use of the term
‘‘secured’’ in criterion (3) above. In this
context, a ‘‘secured’’ instrument is an
instrument that is backed by collateral.
In order to qualify as additional tier 1
capital, an instrument may not be
collateralized, guaranteed by the issuing
organization or an affiliate of the issuing
organization, or subject to any other
arrangement that legally or
economically enhances the seniority of
the instrument relative to more senior
claims. Instruments backed by
collateral, guarantees, or other
arrangements that affect their seniority
are less able to absorb losses than
instruments without such
enhancements. Therefore, instruments
secured by collateral, guarantees, or
other enhancements would not be
included in additional tier 1 capital
under the proposal. The agencies have
adopted this criterion as proposed.
Commenters also asked the agencies
and the FDIC to clarify whether terms
allowing a banking organization to
convert a fixed-rate instrument to a
floating rate in combination with a call
option, without any increase in credit
spread, would constitute an ‘‘incentive
to redeem’’ under criterion (4). The
agencies do not consider the conversion
from a fixed rate to a floating rate (or
from a floating rate to a fixed rate) in
combination with a call option without
any increase in credit spread to
constitute an ‘‘incentive to redeem’’ for
purposes of this criterion. More
specifically, a call option combined
with a change in reference rate where
the credit spread over the second
reference rate is equal to or less than the
initial dividend rate less the swap rate
(that is, the fixed rate paid to the call
date to receive the second reference
rate) would not be considered an
incentive to redeem. For example, if the
initial reference rate is 0.9 percent, the
credit spread over the initial reference
rate is 2 percent (that is, the initial
dividend rate is 2.9 percent), and the
swap rate to the call date is 1.2 percent,
a credit spread over the second
reference rate greater than 1.7 percent
(2.9 percent minus 1.2 percent) would
be considered an incentive to redeem.
The agencies believe that the
clarification above should address the
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commenters’ concerns, and the agencies
are retaining this criterion in the final
rule as proposed.
Several commenters noted that the
proposed requirement that a banking
organization seek prior approval from
its primary Federal supervisor before
exercising a call option is redundant
with the existing requirement that a
banking organization seek prior
approval before reducing regulatory
capital by redeeming a capital
instrument. The agencies believe that
the proposed requirement clarifies
existing requirements and does not add
any new substantive restrictions or
burdens. Including this criterion also
helps to ensure that the regulatory
capital rules provide banking
organizations a complete list of the
requirements applicable to regulatory
capital instruments in one location.
Accordingly, the agencies have retained
this requirement in the final rule.
Banking industry commenters also
asserted that some of the proposed
criteria could have an adverse impact on
ESOPs. Specifically, the commenters
noted that the proposed requirement
that instruments not be callable for at
least five years after issuance could be
problematic for compensation plans that
enable a company to redeem shares after
employment is terminated. Commenters
asked the agencies and the FDIC to
exempt from this requirement stock
issued as part of an ESOP. For the
reasons stated above in the discussion of
common equity tier 1 capital
instruments, under the final rule,
additional tier 1 instruments issued
under an ESOP by a banking
organization that is not publicly traded
are exempt from the criterion that
additional tier 1 instruments not be
callable for at least five years after
issuance. Moreover, similar to the
discussion above regarding the criteria
for common equity tier 1 capital, the
agencies believe that required
compliance with ERISA and ERISArelated tax code requirements alone
should not prevent an instrument from
being included in regulatory capital.
Therefore, the agencies are including a
provision in the final rule to clarify that
the criterion prohibiting a banking
organization from directly or indirectly
funding a capital instrument, the
criterion prohibiting a capital
instrument from being covered by a
guarantee of the banking organization or
from being subject to an arrangement
that enhances the seniority of the
instrument, and the criterion pertaining
to the creation of an expectation that the
instrument will be redeemed, shall not
prevent an instrument issued by a nonpublicly traded banking organization as
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part of an ESOP from being included in
additional tier 1 capital. In addition,
capital instruments held by an ESOP
trust that are unawarded or unearned by
employees or reported as ‘‘temporary
equity’’ under GAAP (in the case of U.S.
SEC registrants) may not be counted as
equity under GAAP and therefore may
not be included in additional tier 1
capital.
Commenters also asked the agencies
and the FDIC to add exceptions for early
calls within five years of issuance in the
case of an ‘‘investment company event’’
or a ‘‘rating agency event,’’ in addition
to the proposed exceptions for
regulatory and tax events. After
considering the comments on these
issues, the agencies have decided to
revise the rule to permit a banking
organization to call an instrument prior
to five years after issuance in the event
that the issuing entity is required to
register as an investment company
pursuant to the Investment Company
Act of 1940.77 The agencies recognize
that the legal and regulatory burdens of
becoming an investment company could
make it uneconomic to leave some
structured capital instruments
outstanding, and thus would permit the
banking organization to call such
instruments early.
In order to ensure the loss-absorption
capacity of additional tier 1 capital
instruments, the agencies have decided
not to revise the rule to permit a
banking organization to include in its
additional tier 1 capital instruments
issued on or after the effective date of
the rule that may be called prior to five
years after issuance upon the occurrence
of a rating agency event. However,
understanding that many currently
outstanding instruments have this
feature, the agencies have decided to
revise the rule to allow an instrument
that may be called prior to five years
after its issuance upon the occurrence of
a rating agency event to be included into
additional tier 1 capital, provided that
(i) the instrument was issued and
included in a banking organization’s tier
1 capital prior to the effective date of the
rule, and (ii) that such instrument meets
all other criteria for additional tier 1
capital instruments under the final rule.
In addition, a number of commenters
reiterated the concern that restrictions
on the payment of dividends from net
income and current and retained
earnings may conflict with state
corporate laws that permit an
organization to issue dividend payments
from its capital surplus accounts. This
criterion for additional tier 1 capital in
the final rule reflects the identical final
77 15
U.S.C. 80 a–1 et seq.
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criterion for common equity tier 1 for
the reasons discussed above with
respect to common equity tier 1 capital.
Commenters also noted that proposed
criterion (10), which requires the paidin amounts of tier 1 capital instruments
to be classified as equity under GAAP
before they may be included in
regulatory capital, generally would
prevent contingent capital instruments,
which are classified as liabilities, from
qualifying as additional tier 1 capital.
These commenters asked the agencies
and the FDIC to revise the rules to
provide that contingent capital
instruments will qualify as additional
tier 1 capital, regardless of their
treatment under GAAP. Another
commenter noted the challenges for U.S.
banking organizations in devising
contingent capital instruments that
would satisfy the proposed criteria, and
noted that if U.S. banking organizations
develop an acceptable instrument, the
instrument likely would initially be
classified as debt instead of equity for
GAAP purposes. Thus, in order to
accommodate this possibility, the
commenter urged the agencies and the
FDIC to revise the criterion to allow the
agencies and the FDIC to permit such an
instrument in additional tier 1 capital
through interpretive guidance or
specifically in the case of a particular
instrument.
The agencies continue to believe that
restricting tier 1 capital instruments to
those classified as equity under GAAP
will help to ensure those instruments’
capacity to absorb losses and further
increase the quality of U.S. banking
organizations’ regulatory capital. The
agencies therefore have decided to
retain this aspect of the proposal. To the
extent that a contingent capital
instrument is considered a liability
under GAAP, a banking organization
may not include the instrument in its
tier 1 capital under the final rule. At
such time as an instrument converts
from debt to equity under GAAP, the
instrument would then satisfy this
criterion.
In the preamble to the proposed rule,
the agencies included a discussion
regarding whether criterion (7) should
be revised to require banking
organizations to reduce the dividend
payment on tier 1 capital instruments to
a penny when a banking organization
reduces dividend payments on a
common equity tier 1 capital instrument
to a penny per share. Such a revision
would increase the capacity of
additional tier 1 instruments to absorb
losses as it would permit a banking
organization to reduce its capital
distributions on additional tier 1
instruments without eliminating
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entirely its common stock dividend.
Commenters asserted that such a
revision would be unnecessary and
could affect the hierarchy of
subordination in capital instruments.
Commenters also claimed the revision
could prove burdensome as it could
substantially increase the cost of raising
capital through additional tier 1 capital
instruments. In light of these comments
the agencies have decided to not modify
criterion (7) to accommodate the
issuance of a penny dividend as
discussed in the proposal.
Several commenters expressed
concern that criterion (7) for additional
tier 1 capital, could affect the tier 1
eligibility of existing noncumulative
perpetual preferred stock. Specifically,
the commenters were concerned that
such a criterion would disallow
contractual terms of an additional tier 1
capital instrument that restrict payment
of dividends on another capital
instrument that is pari passu in
liquidation with the additional tier 1
capital instrument (commonly referred
to as dividend stoppers). Consistent
with Basel III, the agencies agree that
restrictions related to capital
distributions to holders of common
stock instruments and holders of other
capital instruments that are pari passu
in liquidation with such additional tier
1 capital instruments are acceptable,
and have amended this criterion
accordingly for purposes of the final
rule.
After considering the comments on
the proposal, the agencies have decided
to finalize the criteria for additional tier
1 capital instruments with the
modifications discussed above. The
final revised criteria for additional tier
1 capital are set forth in section 20(c)(1)
of the final rule. The agencies expect
that most outstanding noncumulative
perpetual preferred stock that qualifies
as tier 1 capital under the agencies’
general risk-based capital rules will
qualify as additional tier 1 capital under
the final rule.
3. Tier 2 Capital
Consistent with Basel III, under the
proposed rule, tier 2 capital would
equal the sum of: Tier 2 capital
instruments that satisfy the criteria set
forth in section 20(d) of the proposal,
related surplus, total capital minority
interest not included in a banking
organization’s tier 1 capital (subject to
certain limitations and requirements),
and limited amounts of the allowance
for loan and lease losses (ALLL) less any
applicable regulatory adjustments and
deductions. Consistent with the general
risk-based capital rules, when
calculating its total capital ratio using
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the standardized approach, a banking
organization would be permitted to
include in tier 2 capital the amount of
ALLL that does not exceed 1.25 percent
of its standardized total risk-weighted
assets which would not include any
amount of the ALLL. A banking
organization subject to the market risk
rule would exclude its standardized
market risk-weighted assets from the
calculation.78 In contrast, when
calculating its total capital ratio using
the advanced approaches, a banking
organization would be permitted to
include in tier 2 capital the excess of its
eligible credit reserves over its total
expected credit loss, provided the
amount does not exceed 0.6 percent of
its credit risk-weighted assets.
Consistent with Basel III, the agencies
and the FDIC proposed the following
criteria for tier 2 capital instruments:
(1) The instrument is issued and paidin.
(2) The instrument is subordinated to
depositors and general creditors of the
banking organization.
(3) The instrument is not secured, not
covered by a guarantee of the banking
organization or of an affiliate of the
banking organization, and not subject to
any other arrangement that legally or
economically enhances the seniority of
the instrument in relation to more
senior claims.
(4) The instrument has a minimum
original maturity of at least five years.
At the beginning of each of the last five
years of the life of the instrument, the
amount that is eligible to be included in
tier 2 capital is reduced by 20 percent
of the original amount of the instrument
(net of redemptions) and is excluded
from regulatory capital when remaining
maturity is less than one year. In
addition, the instrument must not have
any terms or features that require, or
create significant incentives for, the
banking organization to redeem the
instrument prior to maturity.
(5) The instrument, by its terms, may
be called by the banking organization
only after a minimum of five years
following issuance, except that the
terms of the instrument may allow it to
be called sooner upon the occurrence of
an event that would preclude the
instrument from being included in tier
2 capital, or a tax event. In addition:
(i) The banking organization must
receive the prior approval of its primary
Federal supervisor to exercise a call
option on the instrument.
78 A
banking organization would deduct the
amount of ALLL in excess of the amount permitted
to be included in tier 2 capital, as well as allocated
transfer risk reserves, from its standardized total
risk-weighted risk assets.
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(ii) The banking organization does not
create at issuance, through action or
communication, an expectation the call
option will be exercised.
(iii) Prior to exercising the call option,
or immediately thereafter, the banking
organization must either:
(A) Replace any amount called with
an equivalent amount of an instrument
that meets the criteria for regulatory
capital under section 20 of the proposed
rule; 79 or
(B) Demonstrate to the satisfaction of
the banking organization’s primary
Federal supervisor that following
redemption, the banking organization
would continue to hold an amount of
capital that is commensurate with its
risk.
(6) The holder of the instrument must
have no contractual right to accelerate
payment of principal or interest on the
instrument, except in the event of a
receivership, insolvency, liquidation, or
similar proceeding of the banking
organization.
(7) The instrument has no creditsensitive feature, such as a dividend or
interest rate that is reset periodically
based in whole or in part on the banking
organization’s credit standing, but may
have a dividend rate that is adjusted
periodically independent of the banking
organization’s credit standing, in
relation to general market interest rates
or similar adjustments.
(8) The banking organization, or an
entity that the banking organization
controls, has not purchased and has not
directly or indirectly funded the
purchase of the instrument.
(9) If the instrument is not issued
directly by the banking organization or
by a subsidiary of the banking
organization that is an operating entity,
the only asset of the issuing entity is its
investment in the capital of the banking
organization, and proceeds must be
immediately available without
limitation to the banking organization or
the banking organization’s top-tier
holding company in a form that meets
or exceeds all the other criteria for tier
2 capital instruments under this
section.80
(10) Redemption of the instrument
prior to maturity or repurchase requires
the prior approval of the banking
organization’s primary Federal
supervisor.
(11) For an advanced approaches
banking organization, the governing
agreement, offering circular, or
79 Replacement of tier 2 capital instruments can
be concurrent with redemption of existing tier 2
capital instruments.
80 De minimis assets related to the operation of
the issuing entity can be disregarded for purposes
of this criterion.
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prospectus of an instrument issued after
January 1, 2013, must disclose that the
holders of the instrument may be fully
subordinated to interests held by the
U.S. government in the event that the
banking organization enters into a
receivership, insolvency, liquidation, or
similar proceeding.
The agencies and the FDIC also
proposed to eliminate the inclusion of a
portion of certain unrealized gains on
AFS equity securities in tier 2 capital
given that unrealized gains and losses
on AFS securities would flow through
to common equity tier 1 capital under
the proposed rules.
As a result of the proposed new
minimum common equity tier 1 capital
requirement, higher tier 1 capital
requirement, and the broader goal of
simplifying the definition of tier 2
capital, the proposal eliminated the
existing limitations on the amount of
tier 2 capital that could be recognized in
total capital, as well as the existing
limitations on the amount of certain
capital instruments (that is, term
subordinated debt) that could be
included in tier 2 capital.
Finally, the agencies and the FDIC
proposed to allow an instrument that
qualified as tier 2 capital under the
general risk-based capital rules and that
was issued under the Small Business
Jobs Act of 2010,81 or, prior to October
4, 2010, under the Emergency Economic
Stabilization Act of 2008, to continue to
be includable in tier 2 capital regardless
of whether it met all of the proposed
qualifying criteria.
Several commenters addressed the
proposed eligibility criteria for tier 2
capital. A few banking industry
commenters asked the agencies and the
FDIC to clarify criterion (2) above to
provide that trade creditors are not
among the class of senior creditors
whose claims rank ahead of
subordinated debt holders. In response
to these comments, the agencies note
that the intent of the final rule, with its
requirement that tier 2 capital
instruments be subordinated to
depositors and general creditors, is to
effectively retain the subordination
standards for tier 2 capital subordinated
debt under the general risk-based capital
rules. Therefore, the agencies are
clarifying that under the final rule, and
consistent with the agencies’ general
risk-based capital rules, subordinated
debt instruments that qualify as tier 2
capital must be subordinated to general
creditors, which generally means senior
indebtedness, excluding trade creditors.
Such creditors include at a minimum all
borrowed money, similar obligations
81 Public
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arising from off-balance sheet
guarantees and direct-credit substitutes,
and obligations associated with
derivative products such as interest rate
and foreign-exchange contracts,
commodity contracts, and similar
arrangements, and, in addition, for
depository institutions, depositors.
In addition, one commenter noted
that while many existing banking
organizations’ subordinated debt
indentures contain subordination
provisions, they may not explicitly
include a subordination provision with
respect to ‘‘general creditors’’ of the
banking organization. Thus, they
recommended that this aspect of the
rules be modified to have only
prospective application. The agencies
note that if it is clear from an
instrument’s governing agreement,
offering circular, or prospectus, that the
instrument is subordinated to general
creditors despite not specifically stating
‘‘general creditors,’’ criterion (2) above
is satisfied (that is, criterion (2) should
not be read to mean that the phrase
‘‘general creditors’’ must appear in the
instrument’s governing agreement,
offering circular, or prospectus, as the
case may be).
One commenter also asked whether a
debt instrument that automatically
converts to an equity instrument within
five years of issuance, and that satisfies
all criteria for tier 2 instruments other
than the five-year maturity requirement,
would qualify as tier 2 capital. The
agencies note that because such an
instrument would automatically convert
to a permanent form of regulatory
capital, the five-year maturity
requirement would not apply and, thus,
it would qualify as tier 2 capital. The
agencies have clarified the final rule in
this respect.
Commenters also expressed concern
about the impact of a number of the
proposed criteria on outstanding TruPS.
For example, commenters stated that a
strict reading of criterion (3) above
could exclude certain TruPS under
which the banking organization
guarantees that any payments made by
the banking organization to the trust
will be used by the trust to pay its
obligations to security holders.
However, the proposed rule would not
have disqualified an instrument with
this type of guarantee, which does not
enhance or otherwise alter the
subordination level of an instrument.
Additionally, the commenters asked the
agencies and the FDIC to allow in tier
2 capital instruments that provide for
default and the acceleration of principal
and interest if the issuer banking
organization defers interest payments
for five consecutive years. Commenters
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stated that these exceptions would be
necessary to accommodate existing
TruPS, which generally include such
call, default and acceleration features.
Commenters also asked the agencies
and the FDIC to clarify the use of the
term ‘‘secured’’ in criterion (3). As
discussed above with respect to the
criteria for additional tier 1 capital, a
‘‘secured’’ instrument is an instrument
where payments on the instrument are
secured by collateral. Therefore, under
criterion (3), a collateralized instrument
will not qualify as tier 2 capital.
Instruments secured by collateral are
less able to absorb losses than
instruments without such enhancement.
With respect to subordinated debt
instruments included in tier 2 capital, a
commenter recommended eliminating
criterion (4)’s proposed five-year
amortization requirement, arguing that
that it was unnecessary given other
capital planning requirements that
banking organizations must satisfy. The
agencies declined to adopt the
commenter’s recommendation, as they
believe that the proposed amortization
schedule results in a more accurate
reflection of the loss-absorbency of a
banking organization’s tier 2 capital.
The agencies note that if a banking
organization begins deferring interest
payments on a TruPS instrument
included in tier 2 capital, such an
instrument will be treated as having a
maturity of five years at that point and
the banking organization must begin
excluding the appropriate amount of the
instrument from capital in accordance
with section 20(d)(1)(iv) of the final
rule.
Similar to the comments received on
the criteria for additional tier 1 capital,
commenters asked the agencies and the
FDIC to add exceptions to the
prohibition against call options that
could be exercised within five years of
the issuance of a capital instrument,
specifically for an ‘‘investment company
event’’ and a ‘‘rating agency event.’’
Although the agencies declined to
permit instruments that include
acceleration provisions in tier 2 capital
in the final rule, the agencies believe
that the inclusion in tier 2 capital of
existing TruPS, which allow for
acceleration after five years of interest
deferral, does not raise safety and
soundness concerns. Although the
majority of existing TruPS would not
technically comply with the final rule’s
tier 2 eligibility criteria, the agencies
acknowledge that the inclusion of
existing TruPS in tier 2 capital (until
they are redeemed or they mature)
would benefit certain banking
organizations until they are able to
replace such instruments with new
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capital instruments that fully comply
with the eligibility criteria of the final
rule. Accordingly, the agencies have
decided to permit non-advanced
approaches depository institution
holding companies with over $15
billion in total consolidated assets to
include in tier 2 capital TruPS that are
phased-out of tier 1 capital in tier 2
capital. However, advanced approaches
depository institution holding
companies would not be allowed to
permanently include existing TruPS in
tier 2 capital. Rather, these banking
organizations would include in tier 2
capital TruPS phased out of tier 1
capital from January 1, 2014 to year-end
2015. From January 1, 2016 to year-end
2021, these banking organizations
would be required to phase out TruPS
from tier 2 capital in line with Table 9
of the transitions section of the final
rule.
As with additional tier 1 capital
instruments, the final rule permits a
banking organization to call an
instrument prior to five years after
issuance in the event that the issuing
entity is required to register with the
SEC as an investment company
pursuant to the Investment Company
Act of 1940, for the reasons discussed
above with respect to additional tier 1
capital. Also for the reasons discussed
above with respect to additional tier 1
capital instruments, the agencies have
decided not to permit a banking
organization to include in its tier 2
capital an instrument issued on or after
the effective date of the final rule that
may be called prior to five years after its
issuance upon the occurrence of a rating
agency event. However, the agencies
have decided to allow such an
instrument to be included in tier 2
capital, provided that the instrument
was issued and included in a banking
organization’s tier 1 or tier 2 capital
prior to January 1, 2014, and that such
instrument meets all other criteria for
tier 2 capital instruments under the final
rule.
In addition, similar to the comment
above with respect to the proposed
criteria for additional tier 1 capital
instruments, commenters noted that the
proposed criterion that a banking
organization seek prior approval from
its primary Federal supervisor before
exercising a call option is redundant
with the requirement that a banking
organization seek prior approval before
reducing regulatory capital by
redeeming a capital instrument. Again,
the agencies believe that this proposed
requirement restates and clarifies
existing requirements without adding
any new substantive restrictions, and
that it will help to ensure that the
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regulatory capital rules provide banking
organizations with a complete list of the
requirements applicable to their
regulatory capital instruments.
Therefore, the agencies are retaining the
requirement as proposed.
Under the proposal, an advanced
approaches banking organization may
include in tier 2 capital the excess of its
eligible credit reserves over expected
credit loss (ECL) to the extent that such
amount does not exceed 0.6 percent of
credit risk-weighted assets, rather than
including the amount of ALLL
described above. Commenters asked the
agencies and the FDIC to clarify whether
an advanced approaches banking
organization that is in parallel run
includes in tier 2 capital its ECL or
ALLL (as described above). To clarify,
for purposes of the final rule, an
advanced approaches banking
organization will always include in total
capital its ALLL up to 1.25 percent of
(non-market risk) risk-weighted assets
when measuring its total capital relative
to standardized risk-weighted assets.
When measuring its total capital relative
to its advanced approaches riskweighted assets, as described in section
10(c)(3)(ii) of the final rule, an advanced
approaches banking organization that
has completed the parallel run process
and that has received notification from
its primary Federal supervisor pursuant
to section 121(d) of subpart E must
adjust its total capital to reflect its
excess eligible credit reserves rather
than its ALLL.
Some commenters recommended that
the agencies and the FDIC remove the
limit on the amount of the ALLL
includable in regulatory capital.
Specifically, one commenter
recommended allowing banking
organizations to include ALLL in tier 1
capital equal to an amount of up to 1.25
percent of total risk-weighted assets,
with the balance in tier 2 capital, so that
the entire ALLL would be included in
regulatory capital. Moreover, some
commenters recommended including in
tier 2 capital the entire amount of
reserves held for residential mortgage
loans sold with recourse, given that the
proposal would require a 100 percent
credit conversion factor for such loans.
Consistent with the ALLL treatment
under the general risk-based capital
rules, for purposes of the final rule the
agencies have elected to permit only
limited amounts of the ALLL in tier 2
capital given its limited purpose of
covering incurred rather than
unexpected losses. For similar reasons,
the agencies have further elected not to
recognize in tier 2 capital reserves held
for residential mortgage loans sold with
recourse.
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As described above, a banking
organization that has made an AOCI
opt-out election may incorporate up to
45 percent of any net unrealized gains
on AFS preferred stock classified as an
equity security under GAAP and AFS
equity exposures into its tier 2 capital.
Some commenters requested that the
eligibility criteria for tier 2 capital be
clarified with regard to surplus notes.
For example, commenters suggested that
the requirement for approval of any
payment of principal or interest on a
surplus note by the applicable insurance
regulator is deemed to satisfy the
criterion of the tier 2 capital instrument
for prior approval for redemption of the
instrument prior to maturity by a
Federal banking agency.
As described under the proposal,
surplus notes generally are financial
instruments issued by insurance
companies that are included in surplus
for statutory accounting purposes as
prescribed or permitted by state laws
and regulations, and typically have the
following features: (1) The applicable
state insurance regulator approves in
advance the form and content of the
note; (2) the instrument is subordinated
to policyholders, to claimant and
beneficiary claims, and to all other
classes of creditors other than surplus
note holders; and (3) the applicable state
insurance regulator is required to
approve in advance any interest
payments and principal repayments on
the instrument. The Board notes that a
surplus note could be eligible for
inclusion in tier 2 capital provided that
the note meets the proposed tier 2
capital eligibility criteria. However, the
Board does not consider approval of
payments by an insurance regulator to
satisfy the criterion for approval by a
Federal banking agency. Accordingly,
the Board has adopted the final rule
without change.
After reviewing the comments
received on this issue, the agencies have
determined to finalize the criteria for
tier 2 capital instruments to include the
aforementioned changes. The revised
criteria for inclusion in tier 2 capital are
set forth in section 20(d)(1) of the final
rule.
4. Capital Instruments of Mutual
Banking Organizations
Under the proposed rule, the
qualifying criteria for common equity
tier 1, additional tier 1, and tier 2 capital
generally would apply to mutual
banking organizations. Mutual banking
organizations and industry groups
representing mutual banking
organizations encouraged the agencies
and the FDIC to expand the qualifying
criteria for additional tier 1 capital to
recognize certain cumulative
instruments. These commenters stressed
that mutual banking organizations,
which do not issue common stock, have
fewer options for raising regulatory
capital relative to other types of banking
organizations.
The agencies do not believe that
cumulative instruments are able to
absorb losses sufficiently reliably to be
included in tier 1 capital. Therefore,
after considering these comments, the
agencies have decided not to include in
tier 1 capital under the final rule any
cumulative instrument. This would
include any previously-issued mutual
capital instrument that was included in
the tier 1 capital of mutual banking
organizations under the general riskbased capital rules, but that does not
meet the eligibility requirements for tier
1 capital under the final rule. These
cumulative capital instruments will be
subject to the transition provisions and
phased out of the tier 1 capital of
mutual banking organizations over time,
as set forth in Table 9 of section 300 in
the final rule. However, if a mutual
banking organization develops a new
capital instrument that meets the
qualifying criteria for regulatory capital
under the final rule, such an instrument
may be included in regulatory capital
with the prior approval of the banking
organization’s primary Federal
supervisor under section 20(e) of the
final rule.
The agencies note that the qualifying
criteria for regulatory capital
instruments under the final rule permit
mutual banking organizations to include
in regulatory capital many of their
existing regulatory capital instruments
(for example, non-withdrawable
accounts, pledged deposits, or mutual
capital certificates). The agencies
believe that the quality and quantity of
regulatory capital currently maintained
by most mutual banking organizations
should be sufficient to satisfy the
requirements of the final rule. For those
organizations that do not currently hold
enough capital to meet the revised
minimum requirements, the transition
arrangements are designed to ease the
burden of increasing regulatory capital
over time.
5. Grandfathering of Certain Capital
Instruments
As described above, a substantial
number of commenters objected to the
proposed phase-out of non-qualifying
capital instruments, including TruPS
and cumulative perpetual preferred
stock, from tier 1 capital. Community
banking organizations in particular
expressed concerns that the costs
related to the replacement of such
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capital instruments, which they
generally characterized as safe and lossabsorbent, would be excessive and
unnecessary. Commenters noted that the
proposal was more restrictive than
section 171 of the Dodd-Frank Act,
which requires the phase-out of nonqualifying capital instruments issued
prior to May 19, 2010, only for
depository institution holding
companies with $15 billion or more in
total consolidated assets as of December
31, 2009. Commenters argued that the
agencies and the FDIC were exceeding
Congressional intent by going beyond
what was required under the DoddFrank Act. Commenters requested that
the agencies and the FDIC grandfather
existing TruPS and cumulative
perpetual preferred stock issued by
depository institution holding
companies with less than $15 billion
and 2010 MHCs.
The agencies agree that under the
Dodd-Frank Act the agencies have the
flexibility to permit depository
institution holding companies with less
than $15 billion in total consolidated
assets as of December 31, 2009 and
banking organizations that were mutual
holding companies as of May 19, 2010
(2010 MHCs) to include in additional
tier 1 capital TruPS and cumulative
perpetual preferred stock issued and
included in tier 1 capital prior to May
19, 2010. Although the agencies
continue to believe that TruPS are not
sufficiently loss-absorbing to be
includable in tier 1 capital as a general
matter, the agencies are also sensitive to
the difficulties community banking
organizations often face when issuing
new capital instruments and are aware
of the importance their capacity to lend
plays in local economies. Therefore the
agencies have decided in the final rule
to grandfather such non-qualifying
capital instruments in tier 1 capital
subject to a limit of 25 percent of tier 1
capital elements excluding any nonqualifying capital instruments and after
all regulatory capital deductions and
adjustments applied to tier 1 capital,
which is substantially similar to the
limit in the general risk-based capital
rules. In addition, the agencies
acknowledge that the inclusion of
existing TruPS in tier 2 capital would
benefit certain banking organizations
until they are able to replace such
instruments with new capital
instruments that fully comply with the
eligibility criteria of the final rule.
Accordingly, the agencies have decided
to permit depository institution holding
companies not subject to the advanced
approaches rule with over $15 billion in
total consolidated assets to permanently
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include in tier 2 capital TruPS that are
phased-out of tier 1 capital in
accordance with Table 8 of the
transitions section of the final rule.
6. Agency Approval of Capital Elements
The agencies and the FDIC noted in
the proposal that they believe most
existing regulatory capital instruments
will continue to be includable in
banking organizations’ regulatory
capital. However, over time, capital
instruments that are equivalent in
quality and capacity to absorb losses to
existing instruments may be created to
satisfy different market needs.
Therefore, the agencies and the FDIC
proposed to create a process to consider
the eligibility of such instruments on a
case-by-case basis. Under the proposed
rule, a banking organization must
request approval from its primary
Federal supervisor before including a
capital element in regulatory capital,
unless: (i) Such capital element is
currently included in regulatory capital
under the agencies’ and the FDIC’s
general risk-based capital and leverage
rules and the underlying instrument
complies with the applicable proposed
eligibility criteria for regulatory capital
instruments; or (ii) the capital element
is equivalent, in terms of capital quality
and ability to absorb losses, to an
element described in a previous
decision made publicly available by the
banking organization’s primary Federal
supervisor.
In the preamble to the proposal, the
agencies and the FDIC indicated that
they intend to consult each other when
determining whether a new element
should be included in common equity
tier 1, additional tier 1, or tier 2 capital,
and indicated that once one agency
determines that a capital element may
be included in a banking organization’s
common equity tier 1, additional tier 1,
or tier 2 capital, that agency would
make its decision publicly available,
including a brief description of the
capital element and the rationale for the
conclusion.
The agencies continue to believe that
it is appropriate to retain the flexibility
necessary to consider new instruments
on a case-by-case basis as they are
developed over time to satisfy different
market needs. The agencies have
decided to move the agencies’ authority
in section 20(e)(1) of the proposal to the
agencies’ reservation of authority
provision included in section 1(d)(2)(ii)
of the final rule. Therefore, the agencies
are adopting this aspect of the final rule
substantively as proposed to create a
process to consider the eligibility of
such instruments on a permanent or
temporary basis, in accordance with the
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applicable requirements in subpart C of
the final rule (section 20(e) of the final
rule).
Section 20(e)(1) of the final rule
provides that a banking organization
must receive its primary Federal
supervisor’s prior approval to include a
capital element in its common equity
tier 1 capital, additional tier 1 capital,
or tier 2 capital unless that element: (i)
Was included in the banking
organization’s tier 1 capital or tier 2
capital prior to May 19, 2010 in
accordance with that supervisor’s riskbased capital rules that were effective as
of that date and the underlying
instrument continues to be includable
under the criteria set forth in this
section; or (ii) is equivalent, in terms of
capital quality and ability to absorb
credit losses with respect to all material
terms, to a regulatory capital element
determined by that supervisor to be
includable in regulatory capital
pursuant to paragraph (e)(3) of section
20. In exercising this reservation of
authority, the agencies expect to
consider the requirements for capital
elements in the final rule; the size,
complexity, risk profile, and scope of
operations of the banking organization,
and whether any public benefits would
be outweighed by risk to an insured
depository institution or to the financial
system.
7. Addressing the Point of Non-Viability
Requirements Under Basel III
During the recent financial crisis, the
United States and foreign governments
lent to, and made capital investments
in, banking organizations. These
investments helped to stabilize the
recipient banking organizations and the
financial sector as a whole. However,
because of the investments, the
recipient banking organizations’ existing
tier 2 capital instruments, and (in some
cases) tier 1 capital instruments, did not
absorb the banking organizations’ credit
losses consistent with the purpose of
regulatory capital. At the same time,
taxpayers became exposed to potential
losses.
On January 13, 2011, the BCBS issued
international standards for all additional
tier 1 and tier 2 capital instruments
issued by internationally-active banking
organizations to ensure that such
regulatory capital instruments fully
absorb losses before taxpayers are
exposed to such losses (the Basel nonviability standard). Under the Basel
non-viability standard, all non-common
stock regulatory capital instruments
issued by an internationally-active
banking organization must include
terms that subject the instruments to
write-off or conversion to common
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equity at the point at which either: (1)
The write-off or conversion of those
instruments occurs; or (2) a public
sector injection of capital would be
necessary to keep the banking
organization solvent. Alternatively, if
the governing jurisdiction of the
banking organization has established
laws that require such tier 1 and tier 2
capital instruments to be written off or
otherwise fully absorb losses before
taxpayers are exposed to loss, the
standard is already met. If the governing
jurisdiction has such laws in place, the
Basel non-viability standard states that
documentation for such instruments
should disclose that information to
investors and market participants, and
should clarify that the holders of such
instruments would fully absorb losses
before taxpayers are exposed to loss.82
U.S. law is consistent with the Basel
non-viability standard. The resolution
regime established in Title II, section
210 of the Dodd-Frank Act provides the
FDIC with the authority necessary to
place failing financial companies that
pose a significant risk to the financial
stability of the United States into
receivership.83 The Dodd-Frank Act
provides that this authority shall be
exercised in a manner that minimizes
systemic risk and moral hazard, so that
(1) Creditors and shareholders will bear
the losses of the financial company; (2)
management responsible for the
condition of the financial company will
not be retained; and (3) the FDIC and
other appropriate agencies will take
steps necessary and appropriate to
ensure that all parties, including holders
of capital instruments, management,
directors, and third parties having
responsibility for the condition of the
financial company, bear losses
consistent with their respective
ownership or responsibility.84 Section
11 of the Federal Deposit Insurance Act
has similar provisions for the resolution
of depository institutions.85
Additionally, under U.S. bankruptcy
law, regulatory capital instruments
issued by a company would absorb
losses in bankruptcy before instruments
held by more senior unsecured
creditors.
Consistent with the Basel nonviability standard, under the proposal,
additional tier 1 and tier 2 capital
instruments issued by advanced
approaches banking organizations after
the date on which such organizations
82 See ‘‘Final Elements of the Reforms to Raise the
Quality of Regulatory Capital’’ (January 2011),
available at: https://www.bis.org/press/p110113.pdf.
83 See 12 U.S.C. 5384.
84 See 12 U.S.C. 5384.
85 12 U.S.C. 1821.
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would have been required to comply
with any final rule would have been
required to include a disclosure that the
holders of the instrument may be fully
subordinated to interests held by the
U.S. government in the event that the
banking organization enters into a
receivership, insolvency, liquidation, or
similar proceeding. The agencies are
adopting this provision of the proposed
rule without change.
8. Qualifying Capital Instruments Issued
by Consolidated Subsidiaries of a
Banking Organization
As highlighted during the recent
financial crisis, capital issued by
consolidated subsidiaries and not
owned by the parent banking
organization (minority interest) is
available to absorb losses at the
subsidiary level, but that capital does
not always absorb losses at the
consolidated level. Accordingly, and
consistent with Basel III, the proposed
rule revised limitations on the amount
of minority interest that may be
included in regulatory capital at the
consolidated level to prevent highly
capitalized subsidiaries from overstating
the amount of capital available to absorb
losses at the consolidated organization.
Under the proposal, minority interest
would have been classified as a
common equity tier 1, tier 1, or total
capital minority interest depending on
the terms of the underlying capital
instrument and on the type of
subsidiary issuing such instrument. Any
instrument issued by a consolidated
subsidiary to third parties would have
been required to satisfy the qualifying
criteria under the proposal to be
included in the banking organization’s
common equity tier 1, additional tier 1,
or tier 2 capital, as appropriate. In
addition, common equity tier 1 minority
interest would have been limited to
instruments issued by a depository
institution or a foreign bank that is a
consolidated subsidiary of a banking
organization.
The proposed limits on the amount of
minority interest that could have been
included in the consolidated capital of
a banking organization would have been
based on the amount of capital held by
the consolidated subsidiary, relative to
the amount of capital the subsidiary
would have had to hold to avoid any
restrictions on capital distributions and
discretionary bonus payments under the
capital conservation buffer framework.
For example, a subsidiary with a
common equity tier 1 capital ratio of 8
percent that needs to maintain a
common equity tier 1 capital ratio of
more than 7 percent to avoid limitations
on capital distributions and
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62053
discretionary bonus payments would
have been considered to have ‘‘surplus’’
common equity tier 1 capital and, at the
consolidated level, the banking
organization would not have been able
to include the portion of such surplus
common equity tier 1 capital that is
attributable to third party investors.
In general, the amount of common
equity tier 1 minority interest that could
have been included in the common
equity tier 1 capital of a banking
organization under the proposal would
have been equal to:
(i) The common equity tier 1 minority
interest of the subsidiary minus
(ii) The ratio of the subsidiary’s
common equity tier 1 capital owned by
third parties to the total common equity
tier 1 capital of the subsidiary,
multiplied by the difference between the
common equity tier 1 capital of the
subsidiary and the lower of:
(1) The amount of common equity tier
1 capital the subsidiary must hold to
avoid restrictions on capital
distributions and discretionary bonus
payments, or
(2)(a) the standardized total riskweighted assets of the banking
organization that relate to the
subsidiary, multiplied by
(b) The common equity tier 1 capital
ratio needed by the banking
organization subsidiary to avoid
restrictions on capital distributions and
discretionary bonus payments.
If a subsidiary were not subject to the
same minimum regulatory capital
requirements or capital conservation
buffer framework as the banking
organization, the banking organization
would have needed to assume, for the
purposes of the calculation described
above, that the subsidiary is in fact
subject to the same minimum capital
requirements and the same capital
conservation buffer framework as the
banking organization.
To determine the amount of tier 1
minority interest that could be included
in the tier 1 capital of the banking
organization and the total capital
minority interest that could be included
in the total capital of the banking
organization, a banking organization
would follow the same methodology as
the one outlined previously for common
equity tier 1 minority interest. The
proposal set forth sample calculations.
The amount of tier 1 minority interest
that could have been included in the
additional tier 1 capital of a banking
organization under the proposal was
equivalent to the banking organization’s
tier 1 minority interest, subject to the
limitations outlined above, less any
common equity tier 1 minority interest
included in the banking organization’s
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common equity tier 1 capital. Likewise,
the amount of total capital minority
interest that could have been included
in the tier 2 capital of the banking
organization was equivalent to its total
capital minority interest, subject to the
limitations outlined above, less any tier
1 minority interest that is included in
the banking organization’s tier 1 capital.
Under the proposal, minority interest
related to qualifying common or
noncumulative perpetual preferred
stock directly issued by a consolidated
U.S. depository institution or foreign
bank subsidiary, which is eligible for
inclusion in tier 1 capital under the
general risk-based capital rules without
limitation, generally would qualify for
inclusion in common equity tier 1 and
additional tier 1 capital, respectively,
subject to the proposed limits. However,
under the proposal, minority interest
related to qualifying cumulative
perpetual preferred stock directly issued
by a consolidated U.S. depository
institution or foreign bank subsidiary,
which is eligible for limited inclusion in
tier 1 capital under the general riskbased capital rules, generally would not
have qualified for inclusion in
additional tier 1 capital under the
proposal.
A number of commenters addressed
the proposed limits on the inclusion of
minority interest in regulatory capital.
Commenters generally asserted that the
proposed methodology for calculating
the amount of minority interest that
could be included in regulatory capital
was overly complex, overly
conservative, and would reduce
incentives for bank subsidiaries to issue
capital to third-party investors. Several
commenters suggested that the agencies
and the FDIC should adopt a more
straightforward and simple approach
that would provide a single blanket
limitation on the amount of minority
interest includable in regulatory capital.
For example, one commenter suggested
allowing a banking organization to
include minority interest equal to 18
percent of common equity tier 1 capital.
Another commenter suggested that
minority interest where shareholders
have commitments to provide
additional capital, as well as minority
interest in joint ventures where there are
guarantees or other credit
enhancements, should not be subject to
the proposed limitations.
Commenters also objected to any
limitations on the amount of minority
interest included in the regulatory
capital of a parent banking organization
attributable to instruments issued by a
subsidiary when the subsidiary is a
depository institution. These
commenters stated that restricting such
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minority interest could create a
disincentive for depository institutions
to issue capital instruments directly or
to maintain capital at levels
substantially above regulatory
minimums. To address this concern,
commenters asked the agencies and the
FDIC to consider allowing a depository
institution subsidiary to consider a
portion of its capital above its minimum
as not being part of its ‘‘surplus’’ capital
for the purpose of calculating the
minority interest limitation.
Alternatively, some commenters
suggested allowing depository
institution subsidiaries to calculate
surplus capital independently for each
component of capital.
Several commenters also addressed
the proposed minority interest
limitation as it would apply to
subordinated debt issued by a
depository institution. Generally, these
commenters stated that the proposed
minority interest limitation either
should not apply to such subordinated
debt, or that the limitation should be
more flexible to permit a greater amount
to be included in the total capital of the
consolidated organization. Commenters
also suggested that the agencies and the
FDIC create an exception to the
limitation for bank holding companies
with only a single subsidiary that is a
depository institution. These
commenters indicated that the
limitation should not apply in such a
situation because a BHC that conducts
all business through a single bank
subsidiary is not exposed to losses
outside of the activities of the
subsidiary.
Finally, some commenters pointed
out that the application of the proposed
calculation for the minority interest
limitation was unclear in circumstances
where a subsidiary depository
institution does not have ‘‘surplus’’
capital. With respect to this comment,
the agencies have revised the proposed
rule to specifically provide that the
minority interest limitation will not
apply in circumstances where a
subsidiary’s capital ratios are equal to or
below the level of capital necessary to
meet the minimum capital requirements
plus the capital conservation buffer.
That is, in the final rule the minority
interest limitation would apply only
where a subsidiary has ‘‘surplus’’
capital.
The agencies continue to believe that
the proposed limitations on minority
interest are appropriate, including for
capital instruments issued by depository
institution subsidiaries, tier 2 capital
instruments, and situations in which a
depository institution holding company
conducts the majority of its business
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through a single depository institution
subsidiary. As noted above, the
agencies’ experience during the recent
financial crisis showed that while
minority interest generally is available
to absorb losses at the subsidiary level,
it may not always absorb losses at the
consolidated level. Therefore, the
agencies continue to believe limitations
on including minority interest will
prevent highly-capitalized subsidiaries
from overstating the amount of capital
available to absorb losses at the
consolidated organization. The
increased safety and soundness benefits
resulting from these limitations should
outweigh any compliance burden issues
related to the complexity of the
calculations. Therefore, the agencies are
adopting the proposed treatment of
minority interest without change, except
for the clarification described above.
9. Real Estate Investment Trust
Preferred Capital
A real estate investment trust (REIT)
is a company that is required to invest
in real estate and real estate-related
assets and make certain distributions in
order to maintain a tax-advantaged
status. Some banking organizations have
consolidated subsidiaries that are REITs,
and such REITs may have issued capital
instruments included in the regulatory
capital of the consolidated banking
organization as minority interest under
the general risk-based capital rules.
Under the general risk-based capital
rules, preferred stock issued by a REIT
subsidiary generally can be included in
a banking organization’s tier 1 capital as
minority interest if the preferred stock
meets the eligibility requirements for
tier 1 capital.86 The agencies and the
FDIC interpreted this to require that the
REIT-preferred stock be exchangeable
automatically into noncumulative
perpetual preferred stock of the banking
organization under certain
circumstances. Specifically, the primary
Federal supervisor may direct the
banking organization in writing to
convert the REIT preferred stock into
noncumulative perpetual preferred
stock of the banking organization
because the banking organization: (1)
Became undercapitalized under the PCA
regulations; 87 (2) was placed into
conservatorship or receivership; or (3)
86 12 CFR part 325, subpart B (FDIC); 12 CFR part
3, appendix A, Sec. 2(a)(3) (OCC); see also
Comptroller’s Licensing Manual, Capital and
Dividends, p. 14 (Nov. 2007).
87 12 CFR part 3, appendix A, section 2(a)(3)
(national banks) and 12 CFR 167.5(a)(1)(iii) (Federal
savings associations) (OCC); 12 CFR part 208,
subpart D (Board); 12 CFR part 325, subpart B, 12
CFR part 390, subpart Y (FDIC).
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was expected to become
undercapitalized in the near term.88
Under the proposed rule, the
limitations described previously on the
inclusion of minority interest in
regulatory capital would have applied to
capital instruments issued by
consolidated REIT subsidiaries.
Specifically, preferred stock issued by a
REIT subsidiary that met the proposed
definition of an operating entity (as
defined below) would have qualified for
inclusion in the regulatory capital of a
banking organization subject to the
limitations outlined in section 21 of the
proposed rule only if the REIT preferred
stock met the criteria for additional tier
1 or tier 2 capital instruments outlined
in section 20 of the proposed rules.
Because a REIT must distribute 90
percent of its earnings to maintain its
tax-advantaged status, a banking
organization might be reluctant to
cancel dividends on the REIT preferred
stock. However, for a capital instrument
to qualify as additional tier 1 capital the
issuer must have the ability to cancel
dividends. In cases where a REIT could
maintain its tax status, for example, by
declaring a consent dividend and it has
the ability to do so, the agencies
generally would consider REIT
preferred stock to satisfy criterion (7) of
the proposed eligibility criteria for
additional tier 1 capital instruments.89
The agencies note that the ability to
declare a consent dividend need not be
included in the documentation of the
REIT preferred instrument, but the
banking organization must provide
evidence to the relevant banking agency
that it has such an ability. The agencies
do not expect preferred stock issued by
a REIT that does not have the ability to
declare a consent dividend or otherwise
cancel cash dividends to qualify as tier
1 minority interest under the final rule;
however, such an instrument could
qualify as total capital minority interest
if it meets all of the relevant tier 2
88 See OCC Corporate Decision No. 97–109
(December 1997) available at https://www.occ.gov/
static/interpretations-and-precedents/dec97/cd97109.pdf and the Comptroller’s Licensing Manual,
Capital and Dividends available at https://
www.occ.gov/static/publications/capital3.pdf;
(national banks) and OTS Examination Handbook,
Section 120, appendix A, (page A7) (September
2010), available at https://www.occ.gov/static/newsissuances/ots/exam-handbook/ots-exam-handbook120aa.pdf (Federal savings associations) (OCC); 12
CFR parts 208 and 225, appendix A (Board); 12 CFR
part 325, subpart B (state nonmember banks), and
12 CFR part 390, subpart Y (state savings
associations).
89 A consent dividend is a dividend that is not
actually paid to the shareholders, but is kept as part
of a company’s retained earnings, yet the
shareholders have consented to treat the dividend
as if paid in cash and include it in gross income
for tax purposes.
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capital eligibility criteria under the final
rule.
Commenters requested clarification
on whether a REIT subsidiary would be
considered an operating entity for the
purpose of the final rule. For minority
interest issued from a subsidiary to be
included in regulatory capital, the
subsidiary must be either an operating
entity or an entity whose only asset is
its investment in the capital of the
parent banking organization and for
which proceeds are immediately
available without limitation to the
banking organization. Since a REIT has
assets that are not an investment in the
capital of the parent banking
organization, minority interest in a REIT
subsidiary can be included in the
regulatory capital of the consolidated
parent banking organization only if the
REIT is an operating entity. For
purposes of the final rule, an operating
entity is defined as a company
established to conduct business with
clients with the intention of earning a
profit in its own right. However, certain
REIT subsidiaries currently used by
banking organizations to raise regulatory
capital are not actively managed for the
purpose of earning a profit in their own
right, and therefore, will not qualify as
operating entities for the purpose of the
final rule. Minority interest investments
in REIT subsidiaries that are actively
managed for purposes of earning a profit
in their own right will be eligible for
inclusion in the regulatory capital of the
banking organization subject to the
limits described in section 21 of the
final rule. To the extent that a banking
organization is unsure whether minority
interest investments in a particular REIT
subsidiary will be includable in the
banking organization’s regulatory
capital, the organization should discuss
the concern with its primary Federal
supervisor prior to including any
amount of the minority interest in its
regulatory capital.
Several commenters objected to the
application of the limitations on the
inclusion of minority interest resulting
from noncumulative perpetual preferred
stock issued by REIT subsidiaries.
Commenters noted that to be included
in the regulatory capital of the
consolidated parent banking
organization under the general riskbased capital rules, REIT preferred stock
must include an exchange feature that
allows the REIT preferred stock to
absorb losses at the parent banking
organization through the exchange of
REIT preferred instruments into
noncumulative perpetual preferred
stock of the parent banking
organization. Because of this exchange
feature, the commenters stated that REIT
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preferred instruments should be
included in the tier 1 capital of the
parent consolidated organization
without limitation. Alternatively, some
commenters suggested that the agencies
and the FDIC should allow REIT
preferred instruments to be included in
the tier 2 capital of the consolidated
parent organization without limitation.
Commenters also noted that in light of
the eventual phase-out of TruPS
pursuant to the Dodd-Frank Act, REIT
preferred stock would be the only taxadvantaged means for bank holding
companies to raise tier 1 capital.
According to these commenters,
limiting this tax-advantaged option
would increase the cost of doing
business for many banking
organizations.
After considering these comments, the
agencies have decided not to create
specific exemptions to the limitations
on the inclusion of minority interest
with respect to REIT preferred
instruments. As noted above, the
agencies believe that the inclusion of
minority interest in regulatory capital at
the consolidated level should be limited
to prevent highly-capitalized
subsidiaries from overstating the
amount of capital available to absorb
losses at the consolidated organization.
B. Regulatory Adjustments and
Deductions
1. Regulatory Deductions From
Common Equity Tier 1 Capital
Under the proposal, a banking
organization must deduct from common
equity tier 1 capital elements the items
described in section 22 of the proposed
rule. A banking organization would
exclude the amount of these deductions
from its total risk-weighted assets and
leverage exposure. This section B
discusses the deductions from
regulatory capital elements as revised
for purposes of the final rule.
a. Goodwill and Other Intangibles
(Other Than Mortgage Servicing Assets)
U.S. federal banking statutes generally
prohibit the inclusion of goodwill (as it
is an ‘‘unidentified intangible asset’’) in
the regulatory capital of insured
depository institutions.90 Accordingly,
goodwill and other intangible assets
have long been either fully or partially
excluded from regulatory capital in the
United States because of the high level
of uncertainty regarding the ability of
the banking organization to realize value
from these assets, especially under
90 12
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adverse financial conditions.91 Under
the proposed rule, a banking
organization was required to deduct
from common equity tier 1 capital
elements goodwill and other intangible
assets other than MSAs 92 net of
associated deferred tax liabilities
(DTLs). For purposes of this deduction,
goodwill would have included any
goodwill embedded in the valuation of
significant investments in the capital of
an unconsolidated financial institution
in the form of common stock. This
deduction of embedded goodwill would
have applied to investments accounted
for under the equity method.93
Consistent with Basel III, these items
would have been deducted from
common equity tier 1 capital elements.
MSAs would have been subject to a
different treatment under Basel III and
the proposal, as explained below in this
section.
One commenter sought clarification
regarding the amount of goodwill that
must be deducted from common equity
tier 1 capital elements when a banking
organization has an investment in the
capital of an unconsolidated financial
institution that is accounted for under
the equity method of accounting under
GAAP. The agencies have revised
section 22(a)(1) in the final rule to
clarify that it is the amount of goodwill
that is embedded in the valuation of a
significant investment in the capital of
an unconsolidated financial institution
in the form of common stock that is
accounted for under the equity method,
and reflected in the consolidated
financial statements of the banking
organization that a banking organization
must deduct from common equity tier 1
capital elements.
Another commenter requested
clarification regarding the amount of
embedded goodwill that a banking
organization would be required to
deduct where there are impairments to
the embedded goodwill subsequent to
the initial investment. The agencies note
that, for purposes of the final rule, a
banking organization must deduct from
common equity tier 1 capital elements
any embedded goodwill in the valuation
of significant investments in the capital
of an unconsolidated financial
institution in the form of common stock
91 See 54 FR 4186, 4196 (January 27, 1989)
(Board); 54 FR 4168, 4175 (January 27, 1989) (OCC);
54 FR 11500, 11509 (March 21, 1989) (FDIC).
92 Examples of other intangible assets include
purchased credit card relationships (PCCRs) and
non-mortgage servicing assets.
93 Under GAAP, if there is a difference between
the initial cost basis of the investment and the
amount of underlying equity in the net assets of the
investee, the resulting difference should be
accounted for as if the investee were a consolidated
subsidiary (which may include imputed goodwill).
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net of any related impairments
(subsequent to the initial investment) as
determined under GAAP, not the
goodwill reported on the balance sheet
of the unconsolidated financial
institution.
The proposal did not include a
transition period for the implementation
of the requirement to deduct goodwill
from common equity tier 1 capital. A
number of commenters expressed
concern that this could disadvantage
U.S. banking organizations relative to
those in jurisdictions that permit such a
transition period. The agencies note that
section 221 of FIRREA (12 U.S.C.
1828(n)) requires all unidentifiable
intangible assets (goodwill) acquired
after April 12, 1989, to be deducted
from a banking organization’s capital
elements. The only exception to this
requirement, permitted under 12 U.S.C.
1464(t) (applicable to Federal savings
association), has expired. Therefore,
consistent with the requirements of
section 221 of FIRREA and the general
risk-based capital rules, the agencies
believe that it is not appropriate to
permit any goodwill to be included in
a banking organization’s capital. The
final rule does not include a transition
period for the deduction of goodwill.
b. Gain-on-Sale Associated With a
Securitization Exposure
Under the proposal, a banking
organization would deduct from
common equity tier 1 capital elements
any after-tax gain-on-sale associated
with a securitization exposure. Under
the proposal, gain-on-sale was defined
as an increase in the equity capital of a
banking organization resulting from a
securitization (other than an increase in
equity capital resulting from the
banking organization’s receipt of cash in
connection with the securitization).
A number of commenters requested
clarification that the proposed
deduction for gain-on-sale would not
require a double deduction for MSAs.
According to the commenters, a sale of
loans to a securitization structure that
creates a gain may include an MSA that
also meets the proposed definition of
‘‘gain-on-sale.’’ The agencies agree that
a double deduction for MSAs is not
required, and the final rule clarifies in
the definition of ‘‘gain-on-sale’’ that a
gain-on-sale excludes any portion of the
gain that was reported by the banking
organization as an MSA. The agencies
also note that the definition of gain-onsale was intended to relate only to gains
associated with the sale of loans for the
purpose of traditional securitization.
Thus, the definition of gain-on-sale has
been revised in the final rule to mean an
increase in common equity tier 1 capital
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of the banking organization resulting
from a traditional securitization except
where such an increase results from the
banking organization’s receipt of cash in
connection with the securitization or
initial recognition of an MSA.
c. Defined Benefit Pension Fund Net
Assets
For banking organizations other than
insured depository institutions, the
proposal required the deduction of a net
pension fund asset in calculating
common equity tier 1 capital. A banking
organization was permitted to make
such deduction net of any associated
DTLs. This deduction would be
required where a defined benefit
pension fund is over-funded due to the
high level of uncertainty regarding the
ability of the banking organization to
realize value from such assets. The
proposal did not require a BHC or SLHC
to deduct the net pension fund asset of
its insured depository institution
subsidiary.
The proposal provided that, with
supervisory approval, a banking
organization would not have been
required to deduct defined benefit
pension fund assets to which the
banking organization had unrestricted
and unfettered access.94 In this case, the
proposal established that the banking
organization would have assigned to
such assets the risk weight they would
receive if the assets underlying the plan
were directly owned and included on
the balance sheet of the banking
organization. The proposal set forth that
unrestricted and unfettered access
would mean that a banking organization
would not have been required to request
and receive specific approval from
pension beneficiaries each time it
accessed excess funds in the plan.
One commenter asked whether shares
of a banking organization that are
owned by the banking organization’s
pension fund are subject to deduction.
The agencies note that the final rule
does not require deduction of banking
organization shares owned by the
pension fund. Another commenter
asked for clarification regarding the
treatment of an overfunded pension
asset at an insured depository
institution if the pension plan sponsor
is the parent BHC. The agencies clarify
that the requirement to deduct a defined
benefit pension plan net asset is not
dependent upon the sponsor of the plan;
rather it is dependent upon whether the
94 The FDIC has unfettered access to the pension
fund assets of an insured depository institution’s
pension plan in the event of receivership; therefore,
the agencies determined that an insured depository
institution would not be required to deduct a net
pension fund asset.
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net pension fund asset is an asset of an
insured depository institution. The
agencies and the FDIC also received
questions regarding the appropriate riskweight treatment for a pension fund
asset. As discussed above, with the prior
agency approval, a banking organization
that is not an insured depository
institution may elect to not deduct any
defined benefit pension fund net asset
to the extent such banking organization
has unrestricted and unfettered access
to the assets in that defined benefit
pension fund. Any portion of the
defined benefit pension fund net asset
that is not deducted by the banking
organization must be risk-weighted as if
the banking organization directly holds
a proportional ownership share of each
exposure in the defined benefit pension
fund. For example, if the banking
organization has a defined benefit
pension fund net asset of $10 and it has
unfettered and unrestricted access to the
assets of defined benefit pension fund,
and assuming 20 percent of the defined
benefit pension fund is composed of
assets that are risk-weighted at 100
percent and 80 percent is composed of
assets that are risk-weighted at 300
percent, the banking organization would
risk weight $2 at 100 percent and $8 at
300 percent. This treatment is consistent
with the full look-through approach
described in section 53(b) of the final
rule. If the defined benefit pension fund
invests in the capital of a financial
institution, including an investment in
the banking organization’s own capital
instruments, the banking organization
would risk weight the proportional
share of such exposure in accordance
with the treatment under subparts D or
E, as appropriate.
The agencies are adopting as final this
section of the proposal with the changes
described above.
d. Expected Credit Loss That Exceeds
Eligible Credit Reserves
The proposal required an advanced
approaches banking organization to
deduct from common equity tier 1
capital elements the amount of expected
credit loss that exceeds the banking
organization’s eligible credit reserves.
Commenters sought clarification that
the proposed deduction would not
apply for advanced approaches banking
organizations that have not received the
approval of their primary Federal
supervisor to exit parallel run. The
agencies agree that the deduction would
not apply to banking organizations that
have not received approval from their
primary Federal supervisor to exit
parallel run. In response, the agencies
have revised this provision of the final
rule to apply to a banking organization
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subject to subpart E of the final rule that
has completed the parallel run process
and that has received notification from
its primary Federal supervisor under
section 121(d) of the advanced
approaches rule.
e. Equity Investments in Financial
Subsidiaries
Section 121 of the Gramm-LeachBliley Act allows national banks and
insured state banks to establish entities
known as financial subsidiaries.95 One
of the statutory requirements for
establishing a financial subsidiary is
that a national bank or insured state
bank must deduct any investment in a
financial subsidiary from the depository
institution’s assets and tangible
equity.96 The agencies implemented this
statutory requirement through
regulation at 12 CFR 5.39(h)(1) (OCC)
and 12 CFR 208.73 (Board).
Under section 22(a)(7) of the proposal,
investments by a national bank or
insured state bank in financial
subsidiaries would be deducted entirely
from the bank’s common equity tier 1
capital.97 Because common equity tier 1
capital is a component of tangible
equity, the proposed deduction from
common equity tier 1 would have
automatically resulted in a deduction
from tangible equity. The agencies
believe that the more conservative
treatment is appropriate for financial
subsidiaries given the risks associated
with nonbanking activities, and are
adopting this treatment as proposed.
Therefore, under the final rule, a
depository institution must deduct the
aggregate amount of its outstanding
equity investment in a financial
subsidiary, including the retained
earnings of a subsidiary from common
equity tier 1 capital elements, and the
assets and liabilities of the subsidiary
may not be consolidated with those of
the parent bank.
f. Deduction for Subsidiaries of Savings
Associations That Engage in Activities
That Are Not Permissible for National
Banks
Section 5(t)(5) 98 of HOLA requires a
separate capital calculation for Federal
savings associations for ‘‘investments in
and extensions of credit to any
subsidiary engaged in activities not
permissible for a national bank.’’ This
statutory provision was implemented in
the Federal savings associations’ capital
95 Public Law 106–102, 113 Stat. 1338, 1373 (Nov.
12, 1999).
96 12 U.S.C. 24a(c); 12 U.S.C. 1831w(a)(2).
97 The deduction provided for in the agencies’
existing regulations would be removed and would
exist solely in the final rule.
98 12 U.S.C. 1464(t)(5).
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rules through a deduction from the core
(tier 1) capital of the Federal savings
association for those subsidiaries that
are not ‘‘includable subsidiaries.’’ 99
The OCC proposed to continue the
general risk-based capital treatment of
includable subsidiaries, with some
technical modifications. Aside from
those technical modifications, the
proposal would have transferred,
without substantive change, the current
general regulatory treatment of
deducting subsidiary investments where
a subsidiary is engaged in activities not
permissible for a national bank. Such
treatment is consistent with how a
national bank deducts its equity
investments in financial subsidiaries.
The FDIC proposed an identical
treatment for state savings
associations.100
The OCC received no comments on
this proposed deduction. The final rule
adopts the proposal with one change
and other minor technical edits,
consistent with 12 U.S.C. 1464(t)(5), to
clarify that the required deduction for a
Federal savings association’s investment
in a subsidiary that is engaged in
activities not permissible for a national
bank includes extensions of credit to
such a subsidiary.
2. Regulatory Adjustments to Common
Equity Tier 1 Capital
a. Accumulated Net Gains and Losses
on Certain Cash-Flow Hedges
Consistent with Basel III, under the
proposal, a banking organization would
have been required to exclude from
regulatory capital any accumulated net
gains and losses on cash-flow hedges
relating to items that are not recognized
at fair value on the balance sheet.
This proposed regulatory adjustment
was intended to reduce the artificial
volatility that can arise in a situation in
which the accumulated net gain or loss
of the cash-flow hedge is included in
regulatory capital but any change in the
fair value of the hedged item is not. The
agencies and the FDIC received a
number of comments on this proposed
regulatory capital adjustment. In
general, the commenters noted that
while the intent of the adjustment is to
remove an element that gives rise to
artificial volatility in common equity,
the proposed adjustment may actually
increase volatility in the measure of
common equity tier 1 capital. These
commenters indicated that the proposed
adjustment, together with the proposed
treatment of net unrealized gains and
losses on AFS debt securities, would
create incentives for banking
99 See
100 12
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organizations to avoid hedges that
reduce interest rate risk; shorten
maturity of their investments in AFS
securities; or move their investment
securities portfolio from AFS to HTM.
To address these concerns, commenters
suggested several alternatives, such as
including all accumulated net gains and
losses on cash-flow hedges in common
equity tier 1 capital to match the
proposal to include in common equity
tier 1 capital net unrealized gains and
losses on AFS debt securities; retaining
the provisions in the agencies’ and the
FDIC’s general risk-based capital rules
that exclude most elements of AOCI
from regulatory capital; or using a
principles-based approach to
accommodate variations in the interest
rate management techniques employed
by each banking organization.
Under the final rule, the agencies
have retained the requirement that all
banking organizations subject to the
advanced approaches rule, and those
banking organizations that elect to
include AOCI in common equity tier 1
capital, must subtract from common
equity tier 1 capital elements any
accumulated net gains and must add
any accumulated net losses on cashflow hedges included in AOCI that
relate to the hedging of items that are
not recognized at fair value on the
balance sheet. The agencies believe that
this adjustment removes an element that
gives rise to artificial volatility in
common equity tier 1 capital as it would
avoid a situation in which the changes
in the fair value of the cash-flow hedge
are reflected in capital but the changes
in the fair value of the hedged item are
not.
b. Changes in a Banking Organization’s
Own Credit Risk
The proposal provided that a banking
organization would not be permitted to
include in regulatory capital any change
in the fair value of a liability attributable
to changes in the banking organization’s
own credit risk. In addition, the
proposal would have required advanced
approaches banking organizations to
deduct the credit spread premium over
the risk-free rate for derivatives that are
liabilities. Consistent with Basel III,
these provisions were intended to
prevent a banking organization from
recognizing increases in regulatory
capital resulting from any change in the
fair value of a liability attributable to
changes in the banking organization’s
own creditworthiness. Under the final
rule, all banking organizations not
subject to the advanced approaches rule
must deduct any cumulative gain from
and add back to common equity tier 1
capital elements any cumulative loss
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attributed to changes in the value of a
liability measured at fair value arising
from changes in the banking
organization’s own credit risk. This
requirement would apply to all
liabilities that a banking organization
must measure at fair value under GAAP,
such as derivative liabilities, or for
which the banking organization elects to
measure at fair value under the fair
value option.101
Similarly, advanced approaches
banking organizations must deduct any
cumulative gain from and add back any
cumulative loss to common equity tier
1 capital elements attributable to
changes in the value of a liability that
the banking organization elects to
measure at fair value under GAAP. For
derivative liabilities, advanced
approaches banking organizations must
implement this requirement by
deducting the credit spread premium
over the risk-free rate.
c. Accumulated Other Comprehensive
Income
Under the agencies’ general risk-based
capital rules, most of the components of
AOCI included in a company’s GAAP
equity are not included in a banking
organization’s regulatory capital. Under
GAAP, AOCI includes unrealized gains
and losses on certain assets and
liabilities that are not included in net
income. Among other items, AOCI
includes unrealized gains and losses on
AFS securities; other than temporary
impairment on securities reported as
HTM that are not credit-related;
cumulative gains and losses on cashflow hedges; foreign currency
translation adjustments; and amounts
attributed to defined benefit postretirement plans resulting from the
initial and subsequent application of the
relevant GAAP standards that pertain to
such plans
Under the agencies’ general risk-based
capital rules, banking organizations do
not include most amounts reported in
AOCI in their regulatory capital
calculations. Instead, they exclude these
amounts by subtracting unrealized or
accumulated net gains from, and adding
back unrealized or accumulated net
losses to, equity capital. The only
amounts of AOCI included in regulatory
capital are unrealized losses on AFS
equity securities and foreign currency
translation adjustments, which are
included in tier 1 capital. Additionally,
banking organizations may include up
to 45 percent of unrealized gains on
AFS equity securities in their tier 2
capital.
101 825–10–25 (former Financial Accounting
Standards Board Statement No. 159).
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In contrast, consistent with Basel III,
the proposed rule required banking
organizations to include all AOCI
components in common equity tier 1
capital elements, except gains and
losses on cash-flow hedges where the
hedged item is not recognized on a
banking organization’s balance sheet at
fair value. Unrealized gains and losses
on all AFS securities would flow
through to common equity tier 1 capital
elements, including unrealized gains
and losses on debt securities due to
changes in valuations that result
primarily from fluctuations in
benchmark interest rates (for example,
U.S. Treasuries and U.S. government
agency debt obligations), as opposed to
changes in credit risk.
In the Basel III NPR, the agencies and
the FDIC indicated that the proposed
regulatory capital treatment of AOCI
would better reflect an institution’s
actual risk. In particular, the agencies
and the FDIC stated that while
unrealized gains and losses on AFS debt
securities might be temporary in nature
and reverse over a longer time horizon
(especially when those gains and losses
are primarily attributable to changes in
benchmark interest rates), unrealized
losses could materially affect a banking
organization’s capital position at a
particular point in time and associated
risks should therefore be reflected in its
capital ratios. In addition, the agencies
and the FDIC observed that the
proposed treatment would be consistent
with the common market practice of
evaluating a firm’s capital strength by
measuring its tangible common equity,
which generally includes AOCI.
However, the agencies and the FDIC
also acknowledged that including
unrealized gains and losses related to
debt securities (especially those whose
valuations primarily change as a result
of fluctuations in a benchmark interest
rate) could introduce substantial
volatility in a banking organization’s
regulatory capital ratios. Specifically,
the agencies and the FDIC observed that
for some banking organizations,
including unrealized losses on AFS debt
securities in their regulatory capital
calculations could mean that
fluctuations in a benchmark interest rate
could lead to changes in their PCA
categories from quarter to quarter.
Recognizing the potential impact of
such fluctuations on regulatory capital
management for some institutions, the
agencies and the FDIC described
possible alternatives to the proposed
treatment of unrealized gains and losses
on AFS debt securities, including an
approach that would exclude from
regulatory capital calculations those
unrealized gains and losses that are
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related to AFS debt securities whose
valuations primarily change as a result
of fluctuations in benchmark interest
rates, including U.S. government and
agency debt obligations, GSE debt
obligations, and other sovereign debt
obligations that would qualify for a zero
percent risk weight under the
standardized approach.
A large proportion of commenters
addressed the proposed treatment of
AOCI in regulatory capital. Banking
organizations of all sizes, banking and
other industry groups, public officials
(including members of the U.S.
Congress), and other individuals
strongly opposed the proposal to
include most AOCI components in
common equity tier 1 capital.
Specifically, commenters asserted that
the agencies and the FDIC should not
implement the proposal and should
instead continue to apply the existing
treatment for AOCI that excludes most
AOCI amounts from regulatory capital.
Several commenters stated that the
accounting standards that require
banking organizations to take a charge
against earnings (and thus reduce
capital levels) to reflect credit-related
losses as part of other-than-temporary
impairments already achieve the
agencies’ and the FDIC’s goal to create
regulatory capital ratios that provide an
accurate picture of a banking
organization’s capital position, without
also including AOCI in regulatory
capital. For unrealized gains and losses
on AFS debt securities that typically
result from changes in benchmark
interest rates rather than changes in
credit risk, most commenters expressed
concerns that the value of such
securities on any particular day might
not be a good indicator of the value of
those securities for a banking
organization, given that the banking
organization could hold them until they
mature and realize the amount due in
full. Most commenters argued that the
inclusion of unrealized gains and losses
on AFS debt securities in regulatory
capital could result in volatile capital
levels and adversely affect other
measures tied to regulatory capital, such
as legal lending limits, especially if and
when interest rates rise from their
current historically-low levels.
Accordingly, several commenters
requested that the agencies and the
FDIC permit banking organizations to
remove from regulatory capital
calculations unrealized gains and losses
on AFS debt securities that have low
credit risk but experience price
movements based primarily on
fluctuations in benchmark interest rates.
According to commenters, these debt
securities would include securities
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issued by the United States and other
stable sovereign entities, U.S. agencies
and GSEs, as well as some municipal
entities. One commenter expressed
concern that the proposed treatment of
AOCI would lead banking organizations
to invest excessively in securities with
low volatility. Some commenters also
suggested that unrealized gains and
losses on high-quality asset-backed
securities and high-quality corporate
securities should be excluded from
regulatory capital calculations. The
commenters argued that these
adjustments to the proposal would
allow regulatory capital to reflect
unrealized gains or losses related to the
credit quality of a banking
organization’s AFS debt securities.
Additionally, commenters noted that,
under the proposal, offsetting changes
in the value of other items on a banking
organization’s balance sheet would not
be recognized for regulatory capital
purposes when interest rates change.
For example, the commenters observed
that banking organizations often hold
AFS debt securities to hedge interest
rate risk associated with deposit
liabilities, which are not marked to fair
value on the balance sheet. Therefore,
requiring banking organizations to
include AOCI in regulatory capital
would mean that interest rate
fluctuations would be reflected in
regulatory capital only for one aspect of
this hedging strategy, with the result
that the proposed treatment could
greatly overstate the economic impact
that interest rate changes have on the
safety and soundness of the banking
organization.
Several commenters used sample AFS
securities portfolio data to illustrate
how an upward shift in interest rates
could have a substantial impact on a
banking organization’s capital levels
(depending on the composition of its
AFS portfolio and its defined benefit
postretirement obligations). According
to these commenters, the potential
negative impact on capital levels that
could follow a substantial increase in
interest rates would place significant
strains on banking organizations.
To address the potential impact of
incorporating the volatility associated
with AOCI into regulatory capital,
banking organizations also noted that
they could increase their overall capital
levels to create a buffer above regulatory
minimums, hedge or reduce the
maturities of their AFS debt securities,
or shift more debt securities into their
HTM portfolio. However, commenters
asserted that these strategies would be
complicated and costly, especially for
smaller banking organizations, and
could lead to a significant decrease in
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lending activity. Many community
banking organization commenters
observed that hedging or raising
additional capital may be especially
difficult for banking organizations with
limited access to capital markets, while
shifting more debt securities into the
HTM portfolio would impair active
management of interest rate risk
positions and negatively impact a
banking organization’s liquidity
position. These commenters also
expressed concern that this could be
especially problematic given the
increased attention to liquidity by
banking regulators and industry
analysts.
A number of commenters indicated
that in light of the potential impact of
the proposed treatment of AOCI on a
banking organization’s liquidity
position, the agencies and the FDIC
should, at the very least, postpone
implementing this aspect of the
proposal until after implementation of
the BCBS’s revised liquidity standards.
Commenters suggested that postponing
the implementation of the AOCI
treatment would help to ensure that the
final capital rules do not create
disincentives for a banking organization
to increase its holdings of high-quality
liquid assets. In addition, several
commenters suggested that the agencies
and the FDIC not require banking
organizations to include in regulatory
capital unrealized gains and losses on
assets that would qualify as ‘‘high
quality liquid assets’’ under the BCBS’s
‘‘liquidity coverage ratio’’ under the
Basel III liquidity framework.
Finally, several commenters
addressed the inclusion in AOCI of
actuarial gains and losses on defined
benefit pension fund obligations.
Commenters stated that many banking
organizations, particularly mutual
banking organizations, offer defined
benefit pension plans to attract
employees because they are unable to
offer stock options to employees. These
commenters noted that actuarial gains
and losses on defined benefit
obligations represent the difference
between benefit assumptions and,
among other things, actual investment
experiences during a given year, which
is influenced predominantly by the
discount rate assumptions used to
determine the value of the plan
obligation. The discount rate is tied to
prevailing long-term interest rates at a
point in time each year, and while
market returns on the underlying assets
of the plan and the discount rates may
fluctuate year to year, the underlying
liabilities typically are longer term—in
some cases 15 to 20 years. Therefore,
changing interest rate environments
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could lead to material fluctuations in
the value of a banking organization’s
defined benefit post-retirement fund
assets and liabilities, which in turn
could create material swings in a
banking organization’s regulatory
capital that would not be tied to changes
in the credit quality of the underlying
assets. Commenters stated that the
added volatility in regulatory capital
could lead some banking organizations
to reconsider offering defined benefit
pension plans.
The agencies have considered the
comments on the proposal to
incorporate most elements of AOCI in
regulatory capital, and have taken into
account the potential effects that the
proposed AOCI treatment could have on
banking organizations and their
function in the economy. As discussed
in the proposal, the agencies believe
that the proposed AOCI treatment
results in a regulatory capital measure
that better reflects banking
organizations’ actual risk at a specific
point in time. The agencies also believe
that AOCI is an important indicator that
market observers use to evaluate the
capital strength of a banking
organization.
However, the agencies recognize that
for many banking organizations, the
volatility in regulatory capital that could
result from the proposal could lead to
significant difficulties in capital
planning and asset-liability
management. The agencies also
recognize that the tools used by
advanced approaches banking
organizations and other larger, more
complex banking organizations for
managing interest rate risk are not
necessarily readily available to all
banking organizations.
Therefore, in the final rule, the
agencies have decided to permit those
banking organizations that are not
subject to the advanced approaches riskbased capital rules to elect to calculate
regulatory capital by using the treatment
for AOCI in the agencies’ general riskbased capital rules, which excludes
most AOCI amounts. Such banking
organizations, may make a one-time,
permanent election 102 to effectively
continue using the AOCI treatment
under the general risk-based capital
rules for their regulatory calculations
(‘‘AOCI opt-out election’’) when filing
the Call Report or FR Y–9 series report
for the first reporting period after the
102 This one-time, opt-out selection does not
cover a merger, acquisition or purchase transaction
involving all or substantially all of the assets or
voting stock between two banking organizations of
which only one made an AOCI opt-out election.
The resulting organization may make an AOCI
election with prior agency approval.
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date upon which they become subject to
the final rule.
Pursuant to a separate notice under
the Paperwork Reduction Act, the
agencies intend to propose revisions to
the Call Report and FR Y–9 series report
to implement changes in reporting items
that would correspond to the final rule.
These revisions will include a line item
for banking organizations to indicate
their AOCI opt-out election in their first
regulatory report filed after the date the
banking organization becomes subject to
the final rule. Information regarding the
AOCI opt-out election will be made
available to the public and will be
reflected on an ongoing basis in
publicly-available regulatory reports. A
banking organization that does not make
an AOCI opt-out election on the Call
Report or FR Y–9 series report filed for
the first reporting period after the
effective date of the final rule must
include all AOCI components, except
accumulated net gains and losses on
cash-flow hedges related to items that
are not recognized at fair value on the
balance sheet, in regulatory capital
elements starting the first quarter in
which the banking organization
calculates its regulatory capital
requirements under the final rule.
Consistent with regulatory capital
calculations under the agencies’ general
risk-based capital rules, a banking
organization that makes an AOCI optout election under the final rule must
adjust common equity tier 1 capital
elements by: (1) Subtracting any net
unrealized gains and adding any net
unrealized losses on AFS securities; (2)
subtracting any net unrealized losses on
AFS preferred stock classified as an
equity security under GAAP and AFS
equity exposures; (3) subtracting any
accumulated net gains and adding back
any accumulated net losses on cashflow hedges included in AOCI; (4)
subtracting amounts attributed to
defined benefit postretirement plans
resulting from the initial and
subsequent application of the relevant
GAAP standards that pertain to such
plans (excluding, at the banking
organization’s option, the portion
relating to pension assets deducted
under section 22(a)(5)); and (5)
subtracting any net unrealized gains and
adding any net unrealized losses on
held-to-maturity securities that are
included in AOCI. In addition,
consistent with the general risk-based
capital rules, the banking organization
must incorporate into common equity
tier 1 capital any foreign currency
translation adjustment. A banking
organization may also incorporate up to
45 percent of any net unrealized gains
on AFS preferred stock classified as an
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equity security under GAAP and AFS
equity exposures into its tier 2 capital
elements. However, the primary Federal
supervisor may exclude all or a portion
of these unrealized gains from a banking
organization’s tier 2 capital under the
reservation of authority provision of the
final rule if the primary Federal
supervisor determines that such
preferred stock or equity exposures are
not prudently valued.
The agencies believe that banking
organizations that apply the advanced
approaches rule or that have opted to
use the advanced approaches rule
should already have the systems in
place necessary to manage the added
volatility resulting from the new AOCI
treatment. Likewise, pursuant to the
Dodd-Frank Act, these large, complex
banking organizations are subject to
enhanced prudential standards,
including stress-testing requirements,
and therefore should be prepared to
manage their capital levels through the
types of stressed economic
environments, including environments
with shifting interest rates, that could
lead to substantial changes in amounts
reported in AOCI. Accordingly, under
the final rule, advanced approaches
banking organizations will be required
to incorporate all AOCI components,
except accumulated net gains and losses
on cash-flow hedges that relate to items
that are not measured at fair value on
the balance sheet, into their common
equity tier 1 capital elements according
to the transition provisions set forth in
the final rule.
The final rule additionally provides
that in a merger, acquisition, or
purchase transaction between two
banking organizations that have each
made an AOCI opt-out election, the
surviving entity will be required to
continue with the AOCI opt-out
election, unless the surviving entity is
an advanced approaches banking
organization. Similarly, in a merger,
acquisition, or purchase transaction
between two banking organizations that
have each not made an AOCI opt-out
election, the surviving entity must
continue implementing such treatment
going forward. If an entity surviving a
merger, acquisition, or purchase
transaction becomes subject to the
advanced approaches rule, it is no
longer permitted to make an AOCI optout election and, therefore, must
include most elements of AOCI in
regulatory capital in accordance with
the final rule.
However, following a merger,
acquisition or purchase transaction
involving all or substantially all of the
assets or voting stock between two
banking organizations of which only
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one made an AOCI opt-out election (and
the surviving entity is not subject to the
advanced approaches rule), the
surviving entity must decide whether to
make an AOCI opt-out election by its
first regulatory reporting date following
the consummation of the transaction.103
For example, if all of the equity of a
banking organization that has made an
AOCI opt-out election is acquired by a
banking organization that has not made
such an election, the surviving entity
may make a new AOCI opt-out election
in the Call Report or FR Y–9 series
report filed for the first reporting period
after the effective date of the merger.
The final rule also provides the agencies
with discretion to allow a new AOCI
opt-out election where a merger,
acquisition or purchase transaction
between two banking organizations that
have made different AOCI opt-out
elections does not involve all or
substantially all of the assets or voting
stock of the purchased or acquired
banking organization. In making such a
determination, the agencies may
consider the terms of the merger,
acquisition, or purchase transaction, as
well as the extent of any changes to the
risk profile, complexity, and scope of
operations of the banking organization
resulting from the merger, acquisition,
or purchase transaction. The agencies
may also look to the Bank Merger Act 104
for guidance on the types of transactions
that would allow the surviving entity to
make a new AOCI opt-out election.
Finally, a de novo banking organization
formed after the effective date of the
final rule is required to make a decision
to opt out in the first Call Report or FR
Y–9 series report it is required to file.
The final rule also provides that if a
top-tier depository institution holding
company makes an AOCI opt-out
election, any subsidiary insured
depository institution that is
consolidated by the depository
institution holding company also must
make an AOCI opt-out election. The
agencies are concerned that if some
banking organizations subject to
regulatory capital rules under a common
parent holding company make an AOCI
103 A merger would involve ‘‘all or substantially
all’’ of the assets or voting stock where, for example:
(1) A banking organization buys all of the voting
stock of a target banking organization, except for the
stock of a dissenting, non-controlling minority
shareholder; or (2) the banking organization buys all
of the assets and major business lines of a target
banking organization, but does not purchase a
minor business line of the target. Circumstances in
which the ‘‘all or substantially all’’ standard likely
would not be met would be, for example: (1) A
banking organization buys less than 80 percent of
another banking organization; or (3) a banking
organization buys only three out of four of another
banking organization’s major business lines.
104 12 U.S.C. 1828(c).
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opt-out election and others do not, there
is a potential for these organizations to
engage in capital arbitrage by choosing
to book exposures or activities in the
legal entity for which the relevant
components of AOCI are treated most
favorably.
Notwithstanding the availability of
the AOCI opt-out election under the
final rule, the agencies have reserved
the authority to require a banking
organization to recognize all or some
components of AOCI in regulatory
capital if an agency determines it would
be appropriate given a banking
organization’s risks under the agency’s
general reservation of authority under
the final rule. The agencies will
continue to expect each banking
organization to maintain capital
appropriate for its actual risk profile,
regardless of whether it has made an
AOCI opt-out election. Therefore, the
agencies may determine that a banking
organization with a large portfolio of
AFS debt securities, or that is otherwise
engaged in activities that expose it to
high levels of interest-rate or other risks,
should raise its common equity tier 1
capital level substantially above the
regulatory minimums, regardless of
whether that banking organization has
made an AOCI opt-out election.
d. Investments in Own Regulatory
Capital Instruments
To avoid the double-counting of
regulatory capital, the proposal would
have required a banking organization to
deduct the amount of its investments in
its own capital instruments, including
direct and indirect exposures, to the
extent such instruments are not already
excluded from regulatory capital.
Specifically, the proposal would require
a banking organization to deduct its
investment in its own common equity
tier 1, additional tier 1, and tier 2 capital
instruments from the sum of its
common equity tier 1, additional tier 1,
and tier 2 capital, respectively. In
addition, under the proposal any
common equity tier 1, additional tier 1,
or tier 2 capital instrument issued by a
banking organization that the banking
organization could be contractually
obligated to purchase also would have
been deducted from common equity tier
1, additional tier 1, or tier 2 capital
elements, respectively. The proposal
noted that if a banking organization had
already deducted its investment in its
own capital instruments (for example,
treasury stock) from its common equity
tier 1 capital, it would not need to make
such deductions twice.
The proposed rule would have
required a banking organization to look
through its holdings of an index to
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62061
deduct investments in its own capital
instruments. Gross long positions in
investments in its own regulatory
capital instruments resulting from
holdings of index securities would have
been netted against short positions in
the same underlying index. Short
positions in indexes to hedge long cash
or synthetic positions could have been
decomposed to recognize the hedge.
More specifically, the portion of the
index composed of the same underlying
exposure that is being hedged could
have been used to offset the long
position only if both the exposure being
hedged and the short position in the
index were covered positions under the
market risk rule and the hedge was
deemed effective by the banking
organization’s internal control processes
which would have been assessed by the
primary Federal supervisor of the
banking organization. If the banking
organization found it operationally
burdensome to estimate the investment
amount of an index holding, the
proposal permitted the institution to use
a conservative estimate with prior
approval from its primary Federal
supervisor. In all other cases, gross long
positions would have been allowed to
be deducted net of short positions in the
same underlying instrument only if the
short positions involved no
counterparty risk (for example, the
position was fully collateralized or the
counterparty is a qualifying central
counterparty (QCCP)).
As discussed above, under the
proposal, a banking organization would
be required to look through its holdings
of an index security to deduct
investments in its own capital
instruments. Some commenters asserted
that the burden of the proposed lookthrough approach outweighs its benefits
because it is not likely a banking
organization would re-purchase its own
stock through such indirect means.
These commenters suggested that the
agencies and the FDIC should not
require a look-through test for index
securities on the grounds that they are
not ‘‘covert buybacks,’’ but rather are
incidental positions held within a
banking organization’s trading book,
often entered into on behalf of clients,
customers or counterparties, and are
economically hedged. However, the
agencies believe that it is important to
avoid the double-counting of regulatory
capital, whether held directly or
indirectly. Therefore, the final rule
implements the look-through
requirements of the proposal without
change. In addition, consistent with the
treatment for indirect investments in a
banking organization’s own capital
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instruments, the agencies have clarified
in the final rule that banking
organizations must deduct synthetic
exposures related to investments in own
capital instruments.
e. Definition of Financial Institution
Under the proposed rule, a banking
organization would have been required
to deduct an investment in the capital
of an unconsolidated financial
institution exceeding certain thresholds,
as described below. The proposed
definition of financial institution was
designed to include entities whose
activities and primary business are
financial in nature and therefore could
contribute to interconnectedness in the
financial system. The proposed
definition covered entities whose
primary business is banking, insurance,
investing, and trading, or a combination
thereof, and included BHCs, SLHCs,
nonbank financial institutions
supervised by the Board under Title I of
the Dodd-Frank Act, depository
institutions, foreign banks, credit
unions, insurance companies, securities
firms, commodity pools, covered funds
for purposes of section 13 of the Bank
Holding Company Act and regulations
issued thereunder, companies
‘‘predominantly engaged’’ in financial
activities, non-U.S.-domiciled entities
that would otherwise have been covered
by the definition if they were U.S.domiciled, and any other company that
the agencies and the FDIC determined
was a financial institution based on the
nature and scope of its activities. The
definition excluded GSEs and firms that
were ‘‘predominantly engaged’’ in
activities that are financial in nature but
focus on community development,
public welfare projects, and similar
objectives. Under the proposed
definition, a company would have been
‘‘predominantly engaged’’ in financial
activities if (1) 85 percent or more of the
total consolidated annual gross revenues
(as determined in accordance with
applicable accounting standards) of the
company in either of the two most
recent calendar years were derived,
directly or indirectly, by the company
on a consolidated basis from the
activities; or (2) 85 percent or more of
the company’s consolidated total assets
(as determined in accordance with
applicable accounting standards) as of
the end of either of the two most recent
calendar years were related to the
activities.
The proposed definition of ‘‘financial
institution’’ was also relevant for
purposes of the Advanced Approaches
NPR. Specifically, the proposed rule
would have required banking
organizations to apply a multiplier of
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1.25 to the correlation factor for
wholesale exposures to unregulated
financial institutions that generate a
majority of their revenue from financial
activities. The proposed rule also would
have required advanced approaches
banking organizations to apply a
multiplier of 1.25 to wholesale
exposures to regulated financial
institutions with consolidated assets
greater than or equal to $100 billion.105
The agencies and the FDIC received a
number of comments on the proposed
definition of ‘‘financial institution.’’
Commenters expressed concern that the
definition of a financial institution was
overly broad and stated that it should
not include investments in funds,
commodity pools, or ERISA plans.
Other commenters stated that the
‘‘predominantly engaged’’ test would
impose significant operational burdens
on banking organizations in determining
what companies would be included in
the proposed definition of ‘‘financial
institution.’’ Commenters suggested that
the agencies and the FDIC should risk
weight such exposures, rather than
subjecting them to a deduction from
capital based on the definition of
financial institution.
Some of the commenters noted that
many of the exposures captured by the
financial institution definition may be
risk-weighted under certain
circumstances, and expressed concerns
that overlapping regulation would result
in confusion. For similar reasons,
commenters recommended that the
agencies and the FDIC limit the
definition of financial institution to
specific enumerated entities, such as
regulated financial institutions,
including insured depository
institutions and holding companies,
nonbank financial companies
designated by the Financial Stability
Oversight Council, insurance
companies, securities holding
companies, foreign banks, securities
firms, futures commission merchants,
swap dealers, and security based swap
dealers. Other commenters stated that
the definition should cover only those
entities subject to consolidated
regulatory capital requirements.
Commenters also encouraged the
agencies and the FDIC to adopt
105 The definitions of regulated financial
institutions and unregulated financial institutions
are discussed in further detail in section XII.A of
this preamble. Under the proposal, a ‘‘regulated
financial institution’’ would include a financial
institution subject to consolidated supervision and
regulation comparable to that imposed on U.S.
companies that are depository institutions,
depository institution holding companies, nonbank
financial companies supervised by the Board,
broker dealers, credit unions, insurance companies,
and designated financial market utilities.
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alternatives to the ‘‘predominantly
engaged’’ test for identifying a financial
institution, such as the use of standard
industrial classification codes or legal
entity identifiers. Other commenters
suggested that the agencies and the
FDIC should limit the application of the
‘‘predominantly engaged’’ test in the
definition of ‘‘financial institution’’ to
companies above a specified size
threshold. Similarly, others requested
that the agencies and the FDIC exclude
any company with total assets of less
than $50 billion. Many commenters
indicated that the broad definition
proposed by the agencies and the FDIC
was not required by Basel III and was
unnecessary to promote systemic
stability and avoid interconnectivity.
Some commenters stated that funds
covered by Section 13 of the Bank
Holding Company Act also should be
excluded. Other commenters suggested
that the agencies and the FDIC should
exclude investment funds registered
with the SEC under the Investment
Company Act of 1940 and their foreign
equivalents, while some commenters
suggested methods of narrowing the
definition to cover only leveraged funds.
Commenters also requested that the
agencies and the FDIC clarify that
investment or financial advisory
activities include providing both
discretionary and non-discretionary
investment or financial advice to
customers, and that the definition
would not capture either registered
investment companies or investment
advisers to registered funds.
After considering the comments, the
agencies have modified the definition of
‘‘financial institution’’ to provide more
clarity around the scope of the
definition as well as reduce operational
burden. Separate definitions are
adopted under the advanced approaches
provisions of the final rule for
‘‘regulated financial institution’’ and
‘‘unregulated financial institution’’ for
purposes of calculating the correlation
factor for wholesale exposures, as
discussed in section XII.A of this
preamble.
Under the final rule, the first
paragraph of the definition of a financial
institution includes an enumerated list
of regulated institutions similar to the
list that appeared in the first paragraph
of the proposed definition: A BHC;
SLHC; nonbank financial institution
supervised by the Board under Title I of
the Dodd-Frank Act; depository
institution; foreign bank; credit union;
industrial loan company, industrial
bank, or other similar institution
described in section 2 of the Bank
Holding Company Act; national
association, state member bank, or state
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nonmember bank that is not a
depository institution; insurance
company; securities holding company
as defined in section 618 of the DoddFrank Act; broker or dealer registered
with the SEC; futures commission
merchant and swap dealer, each as
defined in the Commodity Exchange
Act; or security-based swap dealer; or
any designated financial market utility
(FMU). The definition also includes
foreign companies that would be
covered by the definition if they are
supervised and regulated in a manner
similar to the institutions described
above that are included in the first
paragraph of the definition of ‘‘financial
institution.’’ The agencies also have
retained in the final definition of
‘‘financial institution’’ a modified
version of the proposed ‘‘predominantly
engaged’’ test to capture additional
entities that perform certain financial
activities that the agencies believe
appropriately addresses those
relationships among financial
institutions that give rise to concerns
about interconnectedness, while
reducing operational burden. Consistent
with the proposal, a company is
‘‘predominantly engaged’’ in financial
activities for the purposes of the
definition if it meets the test to the
extent the following activities make up
more than 85 percent of the company’s
total assets or gross revenues:
(1) Lending money, securities or other
financial instruments, including
servicing loans;
(2) Insuring, guaranteeing,
indemnifying against loss, harm,
damage, illness, disability, or death, or
issuing annuities;
(3) Underwriting, dealing in, making
a market in, or investing as principal in
securities or other financial instruments;
or
(4) Asset management activities (not
including investment or financial
advisory activities).
In response to comments expressing
concerns regarding operational burden
and potential lack of access to necessary
information in applying the proposed
‘‘predominantly engaged’’ test, the
agencies have revised that portion of the
definition. Now, the banking
organization would only apply the test
if it has an investment in the GAAP
equity instruments of the company with
an adjusted carrying value or exposure
amount equal to or greater than $10
million, or if it owns more than 10
percent of the company’s issued and
outstanding common shares (or similar
equity interest). The agencies believe
that this modification would reduce
burden on banking organizations with
small exposures, while those with larger
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exposures should have sufficient
information as a shareholder to conduct
the predominantly engaged analysis.106
In cases when a banking
organization’s investment in the
banking organization exceeds one of the
thresholds described above, the banking
organization must determine whether
the company is predominantly engaged
in financial activities, in accordance
with the final rule. The agencies believe
that this modification will substantially
reduce operational burden for banking
organizations with investments in
multiple institutions. The agencies also
believe that an investment of $10
million in or a holding of 10 percent of
the outstanding common shares (or
equivalent ownership interest) of an
entity has the potential to create a risk
of interconnectedness, and also makes it
reasonable for the banking organization
to gain information necessary to
understand the operations and activities
of the company in which it has invested
and to apply the proposed
‘‘predominantly engaged’’ test under the
definition. The agencies are clarifying
that, consistent with the proposal,
investment or financial advisers
(whether they provide discretionary or
non-discretionary advisory services) are
not covered under the definition of
financial institution. The revised
definition also specifically excludes
employee benefit plans. The agencies
believe, upon review of the comments,
that employee benefit plans are heavily
regulated under ERISA and do not
present the same kind of risk of
systemic interconnectedness that the
enumerated financial institutions
present. The revised definition also
explicitly excludes investment funds
registered with the SEC under the
Investment Company Act of 1940, as the
agencies believe that such funds create
risks of systemic interconnectedness
largely through their investments in the
capital of financial institutions. These
investments are addressed directly by
the final rule’s treatment of indirect
investments in financial institutions.
Although the revised definition does not
specifically include commodities pools,
under some circumstances a banking
organization’s investment in a
commodities pool might meet the
requirements of the modified
‘‘predominantly engaged’’ test.
Some commenters also requested that
the agencies and the FDIC establish an
asset threshold below which an entity
106 For advanced approaches banking
organizations, for purposes of section 131 of the
final rule, the definition of ‘‘unregulated financial
institution’’ does not include the ownership
limitation in applying the ‘‘predominantly
engaged’’ standard.
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62063
would not be included in the definition
of ‘‘financial institution.’’ The agencies
have not included such a threshold
because they are concerned that it could
create an incentive for multiple
investments and aggregated exposures
in smaller financial institutions, thereby
undermining the rationale underlying
the treatment of investments in the
capital of unconsolidated financial
institutions. The agencies believe that
the definition of financial institution
appropriately captures both large and
small entities engaged in the core
financial activities that the agencies
believe should be addressed by the
definition and associated deductions
from capital. The agencies believe,
however, that the modification to the
‘‘predominantly engaged’’ test, should
serve to alleviate some of the burdens
with which the commenters who made
this point were concerned.
Consistent with the proposal,
investments in the capital of
unconsolidated financial institutions
that are held indirectly (indirect
exposures) are subject to deduction.
Under the proposal, a banking
organization’s entire investment in, for
example, a registered investment
company would have been subject to
deduction from capital. Although those
entities are excluded from the definition
of financial institution in the final rule
unless the ownership threshold is met,
any holdings in the capital instruments
of financial institutions held indirectly
through investment funds are subject to
deduction from capital. More generally,
and as described later in this section of
the preamble, the final rule provides an
explicit mechanism for calculating the
amount of an indirect investment
subject to deduction.
f. The Corresponding Deduction
Approach
The proposals incorporated the Basel
III corresponding deduction approach
for the deductions from regulatory
capital related to reciprocal
crossholdings, non-significant
investments in the capital of
unconsolidated financial institutions,
and non-common stock significant
investments in the capital of
unconsolidated financial institutions.
Under the proposal, a banking
organization would have been required
to make any such deductions from the
same component of capital for which
the underlying instrument would
qualify if it were issued by the banking
organization itself. If a banking
organization did not have a sufficient
amount of a specific regulatory capital
component against which to effect the
deduction, the shortfall would have
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been deducted from the next higher
(that is, more subordinated) regulatory
capital component. For example, if a
banking organization did not have
enough additional tier 1 capital to
satisfy the required deduction, the
shortfall would be deducted from
common equity tier 1 capital elements.
Under the proposal, if the banking
organization invested in an instrument
issued by an financial institution that is
not a regulated financial institution, the
banking organization would have
treated the instrument as common
equity tier 1 capital if the instrument is
common stock (or if it is otherwise the
most subordinated form of capital of the
financial institution) and as additional
tier 1 capital if the instrument is
subordinated to all creditors of the
financial institution except common
shareholders. If the investment is in the
form of an instrument issued by a
regulated financial institution and the
instrument does not meet the criteria for
any of the regulatory capital
components for banking organizations,
the banking organization would treat the
instrument as: (1) Common equity tier 1
capital if the instrument is common
stock included in GAAP equity or
represents the most subordinated claim
in liquidation of the financial
institution; (2) additional tier 1 capital
if the instrument is GAAP equity and is
subordinated to all creditors of the
financial institution and is only senior
in liquidation to common shareholders;
and (3) tier 2 capital if the instrument
is not GAAP equity but it is considered
regulatory capital by the primary
supervisor of the financial institution.
Some commenters sought clarification
on whether, under the corresponding
deduction approach, TruPS would be
deducted from tier 1 or tier 2 capital. In
response to these comments the
agencies have revised the final rule to
clarify the deduction treatment for
investments of non-qualifying capital
instruments, including TruPS, under the
corresponding deduction approach. The
final rule includes a new paragraph
section 22(c)(2)(iii) to provide that if an
investment is in the form of a nonqualifying capital instrument described
in section 300(d) of the final rule, the
banking organization must treat the
instrument as a: (1) Tier 1 capital
instrument if it was included in the
issuer’s tier 1 capital prior to May 19,
2010; or (2) tier 2 capital instrument if
it was included in the issuer’s tier 2
capital (but not eligible for inclusion in
the issuer’s tier 1 capital) prior to May
19, 2010.
In addition, to avoid a potential
circularity issue (related to the
combined impact of the treatment of
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ALLL and the risk-weight treatment for
threshold items that are not deducted
from common equity tier 1 capital) in
the calculation of common equity tier 1
capital, the final rule clarifies that
banking organizations must apply any
deductions under the corresponding
deduction approach resulting from
insufficient amounts of a specific
regulatory capital component after
applying any deductions from the items
subject to the 10 and 15 percent
common equity tier 1 capital deduction
thresholds discussed further below.
This was accomplished by removing
proposed paragraph 22(c)(2)(i) from the
corresponding deduction approach
section and inserting paragraph 22(f).
Under section 22(f) of the final rule, and
as noted above, if a banking
organization does not have a sufficient
amount of a specific component of
capital to effect the required deduction
under the corresponding deduction
approach, the shortfall must be
deducted from the next higher (that is,
more subordinated) component of
regulatory capital.
g. Reciprocal Crossholdings in the
Capital Instruments of Financial
Institutions
A reciprocal crossholding results from
a formal or informal arrangement
between two financial institutions to
swap, exchange, or otherwise intend to
hold each other’s capital instruments.
The use of reciprocal crossholdings of
capital instruments to artificially inflate
the capital positions of each of the
financial institutions involved would
undermine the purpose of regulatory
capital, potentially affecting the stability
of such financial institutions as well as
the financial system.
Under the agencies’ general risk-based
capital rules, reciprocal crossholdings of
capital instruments of banking
organizations are deducted from
regulatory capital. Consistent with Basel
III, the proposal would have required a
banking organization to deduct
reciprocal crossholdings of capital
instruments of other financial
institutions using the corresponding
deduction approach. The final rule
maintains this treatment.
h. Investments in the Banking
Organization’s Own Capital Instruments
or in the Capital of Unconsolidated
Financial Institutions
In the final rule, the agencies made
several non-substantive changes to the
wording in the proposal to clarify that
the amount of an investment in the
banking organization’s own capital
instruments or in the capital of
unconsolidated financial institutions is
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the net long position (as calculated
under section 22(h) of the final rule) of
such investments. The final rule also
clarifies how to calculate the net long
position of these investments, especially
for the case of indirect exposures. It is
the net long position that is subject to
deduction. In addition, the final rule
generally harmonizes the recognition of
hedging for own capital instruments and
for investments in the capital of
unconsolidated financial institutions.
Under the final rule, an investment in
a banking organization’s own capital
instrument is deducted from regulatory
capital and an investment in the capital
of an unconsolidated financial
institution is subject to deduction from
regulatory capital if such investment
exceeds certain thresholds.
An investment in the capital of an
unconsolidated financial institution
refers to the net long position
(calculated in accordance with section
22(h) of the final rule) in an instrument
that is recognized as capital for
regulatory purposes by the primary
supervisor of an unconsolidated
regulated financial institution or in an
instrument that is part of GAAP equity
of an unconsolidated unregulated
financial institution. It includes direct,
indirect, and synthetic exposures to
capital instruments, and excludes
underwriting positions held by a
banking organization for fewer than five
business days.
An investment in the banking
organization’s own capital instrument
means a net long position calculated in
accordance with section 22(h) of the
final rule in the banking organization’s
own common stock instrument, own
additional tier 1 capital instrument or
own tier 2 capital instrument, including
direct, indirect or synthetic exposures to
such capital instruments. An investment
in the banking organization’s own
capital instrument includes any
contractual obligation to purchase such
capital instrument.
The final rule also clarifies that the
gross long position for an investment in
the banking organization’s own capital
instrument or the capital of an
unconsolidated financial institution that
is an equity exposure refers to the
adjusted carrying value (determined in
accordance with section 51(b) of the
final rule). For the case of an investment
in the banking organization’s own
capital instrument or the capital of an
unconsolidated financial institution that
is not an equity exposure, the gross long
position is defined as the exposure
amount (determined in accordance with
section 2 of the final rule).
Under the proposal, the agencies and
the FDIC included the methodology for
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the recognition of hedging and for the
calculation of the net long position
regarding investments in the banking
organization’s own capital instruments
and in investments in the capital of
unconsolidated financial institutions in
the definitions section. However, such
methodology appears in section 22 of
the final rule as the agencies believe it
is more appropriate to include it in the
adjustments and deductions to
regulatory capital section.
The final rule provides that the net
long position is the gross long position
in the underlying instrument (including
covered positions under the market risk
rule) net of short positions in the same
instrument where the maturity of the
short position either matches the
maturity of the long position or has a
residual maturity of at least one year. A
banking organization may only net a
short position against a long position in
the banking organization’s own capital
instrument if the short position involves
no counterparty credit risk. The long
and short positions in the same index
without a maturity date are considered
to have matching maturities. If both the
long position and the short position do
not have contractual maturity dates,
then the positions are considered
maturity-matched. For positions that are
reported on a banking organization’s
regulatory report as trading assets or
trading liabilities, if the banking
organization has a contractual right or
obligation to sell a long position at a
specific point in time, and the
counterparty to the contract has an
obligation to purchase the long position
if the banking organization exercises its
right to sell, this point in time may be
treated as the maturity of the long
position. Therefore, if these conditions
are met, the maturity of the long
position and the short position would
be deemed to be matched even if the
maturity of the short position is less
than one year.
Gross long positions in own capital
instruments or in the capital
instruments of unconsolidated financial
institutions resulting from positions in
an index may be netted against short
positions in the same underlying index.
Short positions in indexes that are
hedging long cash or synthetic positions
may be decomposed to recognize the
hedge. More specifically, the portion of
the index that is composed of the same
underlying exposure that is being
hedged may be used to offset the long
position, provided both the exposure
being hedged and the short position in
the index are trading assets or trading
liabilities, and the hedge is deemed
effective by the banking organization’s
internal control processes, which the
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banking organization’s primary Federal
supervisor has found not to be
inadequate.
An indirect exposure results from a
banking organization’s investment in an
investment fund that has an investment
in the banking organization’s own
capital instrument or the capital of an
unconsolidated financial institution. A
synthetic exposure results from a
banking organization’s investment in an
instrument where the value of such
instrument is linked to the value of the
banking organization’s own capital
instrument or a capital instrument of a
financial institution. Examples of
indirect and synthetic exposures
include: (1) An investment in the capital
of an investment fund that has an
investment in the capital of an
unconsolidated financial institution; (2)
a total return swap on a capital
instrument of the banking organization
or another financial institution; (3) a
guarantee or credit protection, provided
to a third party, related to the third
party’s investment in the capital of
another financial institution; (4) a
purchased call option or a written put
option on the capital instrument of
another financial institution; (5) a
forward purchase agreement on the
capital of another financial institution;
and (6) a trust preferred security
collateralized debt obligation (TruPS
CDO).
Investments, including indirect and
synthetic exposures, in the capital of
unconsolidated financial institutions are
subject to the corresponding deduction
approach if they surpass certain
thresholds described below. With the
prior written approval of the primary
Federal supervisor, for the period of
time stipulated by the supervisor, a
banking organization is not required to
deduct investments in the capital of
unconsolidated financial institutions
described in this section if the
investment is made in connection with
the banking organization providing
financial support to a financial
institution in distress, as determined by
the supervisor. Likewise, a banking
organization that is an underwriter of a
failed underwriting can request
approval from its primary Federal
supervisor to exclude underwriting
positions related to such failed
underwriting held for longer than five
days.
Some commenters requested
clarification that a long position and
short hedging position are considered
‘‘maturity matched’’ if (1) the maturity
period of the short position extends
beyond the maturity period of the long
position or (2) both long and short
positions mature or terminate within the
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same calendar quarter. The agencies
note that they concur with these
commenters’ interpretation of the
maturity matching of long and short
hedging positions.
For purposes of calculating the net
long position in the capital of an
unconsolidated financial institution,
several commenters expressed concern
that allowing banking organizations to
net gross long positions with short
positions only where the maturity of the
short position either matches the
maturity of the long position or has a
maturity of at least one year is not
practical, as some exposures, such as
cash equities, have no maturity. These
commenters expressed concern that
such a maturity requirement could
result in banking organizations
deducting equities held as hedges for
equity swap transactions with a client,
making the latter transactions
uneconomical and resulting in
disruptions to market activity.
Similarly, these commenters argued that
providing customer accommodation
equity swaps could become burdensome
as a strict reading of the proposal could
affect the ability of banking
organizations to offset the equity swap
with the long equity position because
the maturity of the equity swap is
typically less than one year. The
agencies have considered the comments
and have decided to retain the maturity
requirement as proposed. The agencies
believe that the proposed maturity
requirements will reduce the possibility
of ‘‘cliff effects’’ resulting from the
deduction of open equity positions
when a banking organization is unable
to replace the hedge or sell the long
equity position.
i. Indirect Exposure Calculations
The proposal provided that an
indirect exposure would result from a
banking organization’s investment in an
unconsolidated entity that has an
exposure to a capital instrument of a
financial institution, while a synthetic
exposure would result from the banking
organization’s investment in an
instrument where the value of such
instrument is linked to the value of a
capital instrument of a financial
institution. With the exception of index
securities, the proposal did not,
however, provide a mechanism for
calculating the amount of the indirect
exposure that is subject to deduction.
The final rule clarifies the
methodologies for calculating the net
long position related to an indirect
exposure (which is subject to deduction
under the final rule) by providing a
methodology for calculating the gross
long position of such indirect exposure.
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The agencies believe that the options
provided in the final rule will provide
banking organizations with increased
clarity regarding the treatment of
indirect exposures, as well as increased
risk-sensitivity to the banking
organization’s actual potential exposure.
In order to limit the potential
difficulties in determining whether an
unconsolidated entity in fact holds the
banking organization’s own capital or
the capital of unconsolidated financial
institutions, the final rule also provides
that the indirect exposure requirements
only apply when the banking
organization holds an investment in an
investment fund, as defined in the rule.
Accordingly, a banking organization
invested in, for example, a commercial
company is not required to determine
whether the commercial company has
any holdings of the banking
organization’s own capital or the capital
instruments of financial institutions.
The final rule provides that a banking
organization may determine that its
gross long position is equivalent to its
carrying value of its investment in an
investment fund that holds the banking
organization’s own capital or that holds
an investment in the capital of an
unconsolidated financial institution,
which would be subject to deduction
according to section 22(c). Recognizing,
however, that the banking organization’s
exposure to those capital instruments
may be less than its carrying value of its
investment in the investment fund, the
final rule provides two alternatives for
calculating the gross long position of an
indirect exposure. For an indirect
exposure resulting from a position in an
index, a banking organization may, with
the prior approval of its primary Federal
supervisor, use a conservative estimate
of the amount of its investment in its
own capital instruments or the capital
instruments of other financial
institutions. If the investment is held
through an investment fund, a banking
organization may use a look-through
approach similar to the approach used
for risk weighting equity exposures to
investment funds. Under this approach,
a banking organization may multiply the
carrying value of its investment in an
investment fund by either the exact
percentage of the banking organization’s
own capital instrument or capital
instruments of unconsolidated financial
institutions held by the investment fund
or by the highest stated prospectus limit
for such investments held by the
investment fund. Accordingly, if a
banking organization with a carrying
value of $10,000 for its investment in an
investment fund knows that the
investment fund has invested 30 percent
of its assets in the capital of financial
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institutions, then the banking
organization could subject $3,000 (the
carrying value times the percentage
invested in the capital of financial
institutions) to deduction from
regulatory capital. The agencies believe
that the approach is flexible and
benefits a banking organization that
obtains and maintains information
about its investments through
investment funds. It also provides a
simpler calculation method for a
banking organization that either does
not have information about the holdings
of the investment fund or chooses not to
do the more complex calculation.
j. Non-Significant Investments in the
Capital of Unconsolidated Financial
Institutions
The proposal provided that nonsignificant investments in the capital of
unconsolidated financial institutions
would be the net long position in
investments where a banking
organization owns 10 percent or less of
the issued and outstanding common
stock of an unconsolidated financial
institution.
Under the proposal, if the aggregate
amount of a banking organization’s nonsignificant investments in the capital of
unconsolidated financial institutions
exceeds 10 percent of the sum of the
banking organization’s own common
equity tier 1 capital, minus certain
applicable deductions and other
regulatory adjustments to common
equity tier 1 capital (the 10 percent
threshold for non-significant
investments), the banking organization
would have been required to deduct the
amount of the non-significant
investments that are above the 10
percent threshold for non-significant
investments, applying the
corresponding deduction approach.107
Under the proposal, the amount to be
deducted from a specific capital
107 The regulatory adjustments and deductions
applied in the calculation of the 10 percent
threshold for non-significant investments are those
required under sections 22(a) through 22(c)(3) of the
proposal. That is, the required deductions and
adjustments for goodwill and other intangibles
(other than MSAs) net of associated DTLs (when the
banking organization has elected to net DTLs in
accordance with section 22(e)), DTAs that arise
from net operating loss and tax credit carryforwards
net of related valuation allowances and DTLs (in
accordance with section 22(e)), cash-flow hedges
associated with items that are not recognized at fair
value on the balance sheet, excess ECLs (for
advanced approaches banking organizations only),
gains-on-sale on securitization exposures, gains and
losses due to changes in own credit risk on
financial liabilities measured at fair value, defined
benefit pension fund net assets for banking
organizations that are not insured by the FDIC (net
of associated DTLs in accordance with section
22(e)), investments in own regulatory capital
instruments (not deducted as treasury stock), and
reciprocal crossholdings.
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component would be equal to the
amount of a banking organization’s nonsignificant investments in the capital of
unconsolidated financial institutions
exceeding the 10 percent threshold for
non-significant investments multiplied
by the ratio of: (1) The amount of nonsignificant investments in the capital of
unconsolidated financial institutions in
the form of such capital component to
(2) the amount of the banking
organization’s total non-significant
investments in the capital of
unconsolidated financial institutions.
The amount of a banking organization’s
non-significant investments in the
capital of unconsolidated financial
institutions that does not exceed the 10
percent threshold for non-significant
investments would, under the proposal,
generally be assigned the applicable risk
weight under section 32 or section 131,
as applicable (in the case of noncommon stock instruments), section 52
or section 152, as applicable (in the case
of common stock instruments), or
section 53, section 154, as applicable (in
the case of indirect investments via an
investment fund), or, in the case of a
covered position, in accordance with
subpart F, as applicable.
One commenter requested
clarification that a banking organization
would not have to take a ‘‘double
deduction’’ for an investment made in
unconsolidated financial institutions
held through another unconsolidated
financial institution in which the
banking organization has invested. The
agencies note that, under the final rule,
where a banking organization has an
investment in an unconsolidated
financial institution (Institution A) and
Institution A has an investment in
another unconsolidated financial
institution (Institution B), the banking
organization would not be deemed to
have an indirect investment in
Institution B for purposes of the final
rule’s capital thresholds and deductions
because the banking organization’s
investment in Institution A is already
subject to capital thresholds and
deductions. However, if a banking
organization has an investment in an
investment fund that does not meet the
definition of a financial institution, it
must consider the assets of the
investment fund to be indirect holdings.
Some commenters requested
clarification that the deductions for nonsignificant investments in the capital of
unconsolidated financial institutions
may be net of associated DTLs. The
agencies have clarified in the final rule
that a banking organization must deduct
the net long position in non-significant
investments in the capital of
unconsolidated financial institutions,
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net of associated DTLs in accordance
with section 22(e) of the final rule, that
exceeds the 10 percent threshold for
non-significant investments. Under
section 22(e) of the final rule, the
netting of DTLs against assets that are
subject to deduction or fully deducted
under section 22 of the final rule is
permitted but not required.
Other commenters asked the agencies
and the FDIC to confirm that the
proposal would not require that
investments in TruPS CDOs be treated
as investments in the capital of
unconsolidated financial institutions,
but rather treat the investments as
securitization exposures. The agencies
believe that investments in TruPS CDOs
are synthetic exposures to the capital of
unconsolidated financial institutions
and are thus subject to deduction.
Under the final rule, any amounts of
TruPS CDOs that are not deducted are
subject to the securitization treatment.
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k. Significant Investments in the Capital
of Unconsolidated Financial Institutions
That Are Not in the Form of Common
Stock
Under the proposal, a significant
investment in the capital of an
unconsolidated financial institution
would be the net long position in an
investment where a banking
organization owns more than 10 percent
of the issued and outstanding common
stock of the unconsolidated financial
institution. Significant investments in
the capital of unconsolidated financial
institutions that are not in the form of
common stock are investments where
the banking organization owns capital of
an unconsolidated financial institution
that is not in the form of common stock
in addition to 10 percent of the issued
and outstanding common stock of that
financial institution. Such a noncommon stock investment would be
deducted by applying the corresponding
deduction approach. Significant
investments in the capital of
unconsolidated financial institutions
that are in the form of common stock
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62067
would be subject to 10 and 15 percent
common equity tier 1 capital threshold
deductions described below in this
section.
A number of commenters sought
clarification as to whether under section
22(c) of the proposal, a banking
organization may deduct any significant
investments in the capital of
unconsolidated financial institutions
that are not in the form of common
stock net of associated DTLs. The final
rule clarifies that such deductions may
be net of associated DTLs in accordance
with paragraph 22(e) of the final rule.
Other than this revision, the final rule
adopts the proposed rule.
More generally, commenters also
sought clarification on the treatment of
investments in the capital of
unconsolidated financial institutions
(for example, the distinction between
significant and non-significant
investments). Thus, the chart below
summarizes the treatment of
investments in the capital of
unconsolidated financial institutions.
BILLING CODE 4810–33–P
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l. Items Subject to the 10 and 15 Percent
Common Equity Tier 1 Capital
Threshold Deductions
Under the proposal, a banking
organization would have deducted from
the sum of its common equity tier 1
capital elements the amount of each of
the following items that individually
exceeds the 10 percent common equity
tier 1 capital deduction threshold
described below: (1) DTAs arising from
temporary differences that could not be
realized through net operating loss
carrybacks (net of any related valuation
allowances and net of DTLs, as
described in section 22(e) of the
proposal); (2) MSAs, net of associated
DTLs in accordance with section 22(e)
of the proposal; and (3) significant
investments in the capital of
unconsolidated financial institutions in
the form of common stock (referred to
herein as items subject to the threshold
deductions).
Under the proposal, a banking
organization would have calculated the
10 percent common equity tier 1 capital
deduction threshold by taking 10
percent of the sum of a banking
organization’s common equity tier 1
elements, less adjustments to, and
deductions from common equity tier 1
capital required under sections 22(a)
through (c) of the proposal.
As mentioned above in section V.B,
under the proposal banking
organizations would have been required
to deduct from common equity tier 1
capital any goodwill embedded in the
valuation of significant investments in
the capital of unconsolidated financial
institutions in the form of common
stock. A banking organization would
have been allowed to reduce the
investment amount of such significant
investment by the goodwill embedded
in such investment. For example, if a
banking organization has deducted $10
of goodwill embedded in a $100
significant investment in the capital of
an unconsolidated financial institution
in the form of common stock, the
banking organization would be allowed
to reduce the investment amount of
such significant investment by the
amount of embedded goodwill (that is,
the value of the investment would be
$90 for purposes of the calculation of
the amount that would be subject to
deduction under this part of the
proposal).
In addition, under the proposal the
aggregate amount of the items subject to
the threshold deductions that are not
deducted as a result of the 10 percent
common equity tier 1 capital deduction
threshold described above must not
exceed 15 percent of a banking
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organization’s common equity tier 1
capital, as calculated after applying all
regulatory adjustments and deductions
required under the proposal (the 15
percent common equity tier 1 capital
deduction threshold). That is, a banking
organization would have been required
to deduct in full the amounts of the
items subject to the threshold
deductions on a combined basis that
exceed 17.65 percent (the proportion of
15 percent to 85 percent) of common
equity tier 1 capital elements, less all
regulatory adjustments and deductions
required for the calculation of the 10
percent common equity tier 1 capital
deduction threshold mentioned above,
and less the items subject to the 10 and
15 percent deduction thresholds. As
described below, the proposal required
a banking organization to include the
amounts of these three items that are not
deducted from common equity tier 1
capital in its risk-weighted assets and
assign a 250 percent risk weight to
them.
Some commenters asserted that
subjecting DTAs resulting from net
unrealized losses in an investment
portfolio to the proposed 10 percent
common equity tier 1 capital deduction
threshold under section 22(d) of the
proposal would result in a ‘‘double
deduction’’ in that the net unrealized
losses would have already been
included in common equity tier 1
through the AOCI treatment. Under
GAAP, net unrealized losses recognized
in AOCI are reported net of tax effects
(that is, taxes that give rise to DTAs).
The tax effects related to net unrealized
losses would reduce the amount of net
unrealized losses reflected in common
equity tier 1 capital. Given that the tax
effects reduce the losses that would
otherwise accrue to common equity tier
1 capital, the agencies are of the view
that subjecting these DTAs to the 10
percent limitation would not result in a
‘‘double deduction.’’
More generally, several commenters
noted that the proposed 10 and 15
percent common equity tier 1 capital
deduction thresholds and the proposed
250 percent risk-weight are unduly
punitive. Commenters recommended
several alternatives including, for
example, that the agencies and the FDIC
should only retain the 10 percent limit
on each threshold item but eliminate the
15 percent aggregate limit. The agencies
believe that the proposed thresholds are
appropriate as they increase the quality
and loss-absorbency of regulatory
capital, and are therefore adopting the
proposed deduction thresholds as final.
The agencies realize that these stricter
limits on threshold items may require
banking organizations to make
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appropriate changes in their capital
structure or business model, and thus
have provided a lengthy transition
period to allow banking organizations to
adequately plan for the new limits.
Under section 475 of the Federal
Deposit Insurance Corporation
Improvement Act of 1991 (FDICIA) (12
U.S.C. 1828 note), the amount of readily
marketable purchased mortgage
servicing rights (PMSRs) that a banking
organization may include in regulatory
capital cannot be more than 90 percent
of their fair value. In addition to this
statutory requirement, the general riskbased capital rules require the same
treatment for all MSAs, including
PMSRs. Under the proposed rule, if the
amount of MSAs a banking organization
deducts after applying the 10 percent
and 15 percent common equity tier 1
deduction threshold is less than 10
percent of the fair value of its MSAs,
then the banking organization would
have deducted an additional amount of
MSAs so that the total amount of MSAs
deducted is at least 10 percent of the fair
value of its MSAs.
Some commenters requested removal
of the 90 percent MSA fair value
limitation, including for PMSRs under
FDICIA. These commenters note that
section 475(b) of FDICIA provides the
agencies and the FDIC with authority to
remove the 90 percent limitation on
PMSRs, subject to a joint determination
by the agencies and the FDIC that its
removal would not have an adverse
effect on the deposit insurance fund or
the safety and soundness of insured
depository institutions. The commenters
asserted that removal of the 90 percent
limitation would be appropriate because
other provisions of the proposal
pertaining to MSAs (including PMSRs)
would require more capital to be
retained even if the fair value limitation
were removed.
The agencies agree with these
commenters and, pursuant to section
475(b) of FDICIA, have determined that
PMSRs may be valued at not more than
100 percent of their fair value, because
the capital treatment of PMSRs in the
final rule (specifically, the deduction
approach for MSAs (including PMSRs)
exceeding the 10 and 15 common equity
deduction thresholds and the 250
percent risk weight applied to all MSAs
not subject to deduction) is more
conservative than the FDICIA fair value
limitation and the 100 percent risk
weight applied to MSAs under existing
rules and such approach will not have
an adverse effect on the deposit
insurance fund or safety and soundness
of insured depository institutions. For
the same reasons, the agencies are also
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removing the 90 percent fair value
limitation for all other MSAs.
Commenters also provided a variety
of recommendations related to the
proposed limitations on the inclusion of
MSAs in regulatory capital. For
instance, some commenters advocated
removing the proposed deduction
provision for hedged and commercial
and multifamily-related MSAs, as well
as requested an exemption from the
proposed deduction requirement for
community banking organizations with
less than $10 billion.
Other commenters recommended
increasing the amount of MSAs
includable in regulatory capital. For
example, one commenter recommended
that MSAs should be limited to 100
percent of tier l capital if the underlying
loans are prudently underwritten.
Another commenter requested that the
final rule permit thrifts and commercial
banking organizations to include in
regulatory capital MSAs equivalent to
50 and 25 percent of tier 1 capital,
respectively.
Several commenters also objected to
the proposed risk weights for MSAs,
asserting that a 250 percent risk weight
for an asset that is marked-to-fair value
quarterly is unreasonably punitive and
that a 100 percent risk weight should
apply; that MSAs allowable in capital
should be increased, at a minimum, to
30 percent of tier 1 capital, with a risk
weight of no greater than 50 percent for
existing MSAs; that commercial MSAs
should continue to be subject to the risk
weighting and deduction methodology
under the general risk-based capital
rules; and that originated MSAs should
retain the same risk weight treatment
under the general risk-based capital
rules given that the ability to originate
new servicing to replace servicing lost
to prepayment in a falling-rate
environment provides for a substantial
hedge. Another commenter
recommended that the agencies and the
FDIC grandfather all existing MSAs that
are being fair valued on banking
organizations’ balance sheets and
exclude MSAs from the proposed 15
percent deduction threshold.
After considering these comments, the
agencies are adopting the proposed
limitation on MSAs includable in
common equity tier 1 capital without
change in the final rule. MSAs, like
other intangible assets, have long been
either fully or partially excluded from
regulatory capital in the United States
because of the high level of uncertainty
regarding the ability of banking
organizations to realize value from these
assets, especially under adverse
financial conditions.
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m. Netting of Deferred Tax Liabilities
Against Deferred Tax Assets and Other
Deductible Assets
Under the proposal, banking
organizations would have been
permitted to net DTLs against assets
(other than DTAs) subject to deduction
under section 22 of the proposal,
provided the DTL is associated with the
asset and the DTL would be
extinguished if the associated asset
becomes impaired or is derecognized
under GAAP. Likewise, banking
organizations would be prohibited from
using the same DTL more than once for
netting purposes. This practice would
be generally consistent with the
approach that the agencies currently
take with respect to the netting of DTLs
against goodwill.
With respect to the netting of DTLs
against DTAs, under the proposal the
amount of DTAs that arise from net
operating loss and tax credit
carryforwards, net of any related
valuation allowances, and the amount of
DTAs arising from temporary
differences that the banking
organization could not realize through
net operating loss carrybacks, net of any
related valuation allowances, could be
netted against DTLs if certain conditions
are met.
The agencies and the FDIC received
numerous comments recommending
changes to and seeking clarification on
various aspects of the proposed
treatment of deferred taxes. Certain
commenters asked whether deductions
of significant and non-significant
investments in the capital of
unconsolidated financial institutions
under section 22(c)(4) and 22(c)(5) of
the proposed rule may be net of
associated DTLs. A commenter also
recommended that a banking
organization be permitted to net a DTA
against a fair value measurement or
similar adjustment to an asset (for
example, in the case of a certain cashflow hedges) or a liability (for example,
in the case of changes in the fair value
of a banking organization’s liabilities
attributed to changes in the banking
organization’s own credit risk) that is
associated with the adjusted value of the
asset or liability that itself is subject to
a capital adjustment or deduction under
the Basel III NPR. These DTAs would be
derecognized under GAAP if the
adjustment were reversed. Accordingly,
one commenter recommended that
proposed text in section 22(e) be revised
to apply to netting of DTAs as well as
DTLs.
The agencies agree that for regulatory
capital purposes, a banking organization
may exclude from the deduction
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thresholds DTAs and DTLs associated
with fair value measurement or similar
adjustments to an asset or liability that
are excluded from common equity tier
1 capital under the final rule. The
agencies note that GAAP requires net
unrealized gains and losses 108
recognized in AOCI to be recorded net
of deferred tax effects. Moreover, under
the agencies’ general risk-based capital
rules and associated regulatory
reporting instructions, banking
organizations must deduct certain net
unrealized gains, net of applicable taxes,
and add back certain net unrealized
losses, again, net of applicable taxes.
Permitting banking organizations to
exclude net unrealized gains and losses
included in AOCI without netting of
deferred tax effects would cause a
banking organization to overstate the
amount of net unrealized gains and
losses excluded from regulatory capital
and potentially overstate or understate
deferred taxes included in regulatory
capital.
Accordingly, under the final rule,
banking organizations must make all
adjustments to common equity tier 1
capital under section 22(b) of the final
rule net of any associated deferred tax
effects. In addition, banking
organizations may make all deductions
from common equity tier 1 capital
elements under section 22(c) and (d) of
the final rule net of associated DTLs, in
accordance with section 22(e) of the
final rule.
Commenters also sought clarification
as to whether banking organizations
may change from reporting period to
reporting period their decision to net
DTLs against DTAs as opposed to
netting DTLs against other assets subject
to deduction. Consistent with the
agencies’ general risk-based capital
rules, the final rule permits, but does
not require, a banking organization to
net DTLs associated with items subject
to regulatory deductions from common
equity tier 1 capital under section 22(a).
The agencies’ general risk-based capital
rules do not explicitly address whether
or how often a banking organization
may change its DTL netting approach
for items subject to deduction, such as
goodwill and other intangible assets.
If a banking organization elects to
either net DTLs against DTAs or to net
DTLs against other assets subject to
deduction, the final rule requires that it
must do so consistently. For example, a
banking organization that elects to
deduct goodwill net of associated DTLs
will be required to continue that
108 The word ‘‘net’’ in the term ‘‘net unrealized
gains and losses’’ refers to the netting of gains and
losses before tax.
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practice for all future reporting periods.
Under the final rule, a banking
organization must obtain approval from
its primary Federal supervisor before
changing its approach for netting DTLs
against DTAs or assets subject to
deduction under section 22(a), which
would be permitted, for example, in
situations where a banking organization
merges with or acquires another banking
organization, or upon a substantial
change in a banking organization’s
business model.
Commenters also asked whether
banking organizations would be
permitted or required to exclude (from
the amount of DTAs subject to the
threshold deductions under section
22(d) of the proposal) deferred tax assets
and liabilities relating to net unrealized
gains and losses reported in AOCI that
are subject to: (1) Regulatory
adjustments to common equity tier 1
capital (section 22(b) of the proposal),
(2) deductions from regulatory capital
related to investments in capital
instruments (section 22(c) of the
proposal), and (3) items subject to the 10
and 15 percent common equity tier 1
capital deduction thresholds (section
22(d) of the proposal).
Under the agencies’ general risk-based
capital rules, before calculating the
amount of DTAs subject to the DTA
limitations for inclusion in tier 1
capital, a banking organization may
eliminate the deferred tax effects of any
net unrealized gains and losses on AFS
debt securities. A banking organization
that adopts a policy to eliminate such
deferred tax effects must apply that
approach consistently in all future
calculations of the amount of
disallowed DTAs.
For purposes of the final rule, the
agencies have decided to permit
banking organizations to eliminate from
the calculation of DTAs subject to
threshold deductions under section
22(d) of the final rule the deferred tax
effects associated with any items that
are subject to regulatory adjustment to
common equity tier 1 capital under
section 22(b). A banking organization
that elects to eliminate such deferred tax
effects must continue that practice
consistently from period to period. A
banking organization must obtain
approval from its primary Federal
supervisor before changing its election
to exclude or not exclude these amounts
from the calculation of DTAs.
Additionally, the agencies have decided
to require DTAs associated with any net
unrealized losses or differences between
the tax basis and the accounting basis of
an asset pertaining to items (other than
those items subject to adjustment under
section 22(b)) that are: (1) Subject to
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deduction from common equity tier 1
capital under section 22(c) or (2) subject
to the threshold deductions under
section 22(d) to be subject to the
threshold deductions under section
22(d) of the final rule.
Commenters also sought clarification
as to whether banking organizations
would be required to compute DTAs
and DTLs quarterly for regulatory
capital purposes. In this regard,
commenters stated that GAAP requires
annual computation of DTAs and DTLs,
and that more frequent computation
requirements for regulatory capital
purposes would be burdensome.
Some DTA and DTL items must be
adjusted at least quarterly, such as DTAs
and DTLs associated with certain gains
and losses included in AOCI. Therefore,
the agencies expect banking
organizations to use the DTA and DTL
amounts reported in the regulatory
reports for balance sheet purposes to be
used for regulatory capital calculations.
The final rule does not require banking
organizations to perform these
calculations more often than would
otherwise be required in order to meet
quarterly regulatory reporting
requirements.
A few commenters also asked whether
the agencies and the FDIC would
continue to allow banking organizations
to use DTLs embedded in the carrying
value of a leveraged lease to reduce the
amount of DTAs subject to the 10
percent and 15 percent common equity
tier 1 capital deduction thresholds
contained in section 22(d) of the
proposal. The valuation of a leveraged
lease acquired in a business
combination gives recognition to the
estimated future tax effect of the
remaining cash-flows of the lease.
Therefore, any future tax liabilities
related to an acquired leveraged lease
are included in the valuation of the
leveraged lease, and are not separately
reported under GAAP as DTLs. This can
artificially increase the amount of net
DTAs reported by banking organizations
that acquire a leveraged lease portfolio
under purchase accounting.
Accordingly, the agencies’ currently
allow banking organizations to treat
future taxes payable included in the
valuation of a leveraged lease portfolio
as a reversing taxable temporary
difference available to support the
recognition of DTAs.109 The final rule
amends the proposal by explicitly
109 Temporary differences arise when financial
events or transactions are recognized in one period
for financial reporting purposes and in another
period, or periods, for tax purposes. A reversing
taxable temporary difference is a temporary
difference that produces additional taxable income
future periods.
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62071
permitting a banking organization to use
the DTLs embedded in the carrying
value of a leveraged lease to reduce the
amount of DTAs consistent with section
22(e).
In addition, commenters asked the
agencies and the FDIC to clarify whether
a banking organization is required to
deduct from the sum of its common
equity tier 1 capital elements net DTAs
arising from timing differences that the
banking organization could realize
through net operating loss carrybacks.
The agencies confirm that under the
final rule, DTAs that arise from
temporary differences that the banking
organization may realize through net
operating loss carrybacks are not subject
to the 10 percent and 15 percent
common equity tier 1 capital deduction
thresholds (deduction thresholds). This
is consistent with the agencies’ general
risk-based capital rules, which do not
limit DTAs that can potentially be
realized from taxes paid in prior
carryback years. However, consistent
with the proposal, the final rule requires
that banking organizations deduct from
common equity tier 1 capital elements
the amount of DTAs arising from
temporary differences that the banking
organization could not realize through
net operating loss carrybacks that
exceed the deduction thresholds under
section 22(d) of the final rule.
Some commenters recommended that
the agencies and the FDIC retain the
provision in the agencies’ and the
FDIC’s general risk-based capital rules
that permits a banking organization to
measure the amount of DTAs subject to
inclusion in tier 1 capital by the amount
of DTAs that the banking organization
could reasonably be expected to realize
within one year, based on its estimate of
future taxable income.110 In addition,
commenters argued that the full
deduction of net operating loss and tax
credit carryforwards from common
equity tier 1 capital is an inappropriate
reaction to concerns about DTAs as an
element of capital, and that there are
110 Under the agencies’ general risk-based capital
rules, a banking organization generally must deduct
from tier 1 capital DTAs that are dependent upon
future taxable income, which exceed the lesser of
either: (1) The amount of DTAs that the bank could
reasonably expect to realize within one year of the
quarter-end regulatory report, based on its estimate
of future taxable income for that year, or (2) 10
percent of tier 1 capital, net of goodwill and all
intangible assets other than purchased credit card
relationships, and servicing assets. See 12 CFR part
3, appendix A, section 2(c)(1)(iii) (national banks)
and 12 CFR 167.12(h)(1)(i) (Federal savings
associations (OCC); 12 CFR part 208, appendix A,
section 2(b)(4), 12 CFR part 225, appendix A,
section 2(b)(4) (Board); 12 CFR part 325, appendix
A section I.A.1.iii(a) (state nonmember banks), and
12 CFR 390.465(a)(2)(vii) (state savings
associations).
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appropriate circumstances where an
institution should be allowed to include
the value of its DTAs related to net
operating loss carryforwards in
regulatory capital.
The deduction thresholds for DTAs in
the final rule are intended to address the
concern that GAAP standards for DTAs
could allow banking organizations to
include in regulatory capital excessive
amounts of DTAs that are dependent
upon future taxable income. The
concern is particularly acute when
banking organizations begin to
experience financial difficulty. In this
regard, the agencies and the FDIC
observed that as the recent financial
crisis began, many banking
organizations that had included DTAs
in regulatory capital based on future
taxable income were no longer able to
do so because they projected more than
one year of losses for tax purposes.
The agencies note that under the
proposal and final rule, DTAs that arise
from temporary differences that the
banking organization may realize
through net operating loss carrybacks
are not subject to the deduction
thresholds and will be subject to a risk
weight of 100 percent. Further, banking
organizations will continue to be
permitted to include some or all of their
DTAs that are associated with timing
differences that are not realizable
through net operating loss carrybacks in
regulatory capital. In this regard, the
final rule strikes an appropriate balance
between prudential concerns and
practical considerations about the
ability of banking organizations to
realize DTAs.
The proposal stated: ‘‘A [BANK] is not
required to deduct from the sum of its
common equity tier 1 capital elements
net DTAs arising from timing
differences that the [BANK] could
realize through net operating loss
carrybacks (emphasis added).’’ 111
Commenters requested that the agencies
and the FDIC clarify that the word ‘‘net’’
in this sentence was intended to refer to
DTAs ‘‘net of valuation allowances.’’
The agencies have amended section
22(e) of the final rule text to clarify that
the word ‘‘net’’ in this instance was
intended to refer to DTAs ‘‘net of any
related valuation allowances and net of
DTLs.’’
In addition, a commenter requested
that the agencies and the FDIC remove
the condition in section 22(e) of the
final rule providing that only DTAs and
DTLs that relate to taxes levied by the
same taxing authority may be offset for
purposes of the deduction of DTAs. This
111 See footnote 14, 77 FR 52863 (August 30,
2012).
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commenter notes that under a GAAP, a
company generally calculates its DTAs
and DTLs relating to state income tax in
the aggregate by applying a blended
state rate. Thus, banking organizations
do not typically track DTAs and DTLs
on a state-by-state basis for financial
reporting purposes.
The agencies recognize that under
GAAP, if the tax laws of the relevant
state and local jurisdictions do not differ
significantly from federal income tax
laws, then the calculation of deferred
tax expense can be made in the
aggregate considering the combination
of federal, state, and local income tax
rates. The rate used should consider
whether amounts paid in one
jurisdiction are deductible in another
jurisdiction. For example, since state
and local taxes are deductible for federal
purposes, the aggregate combined rate
would generally be (1) the federal tax
rate plus (2) the state and local tax rates,
minus (3) the federal tax effect of the
deductibility of the state and local taxes
at the federal tax rate. Also, for financial
reporting purposes, consistent with
GAAP, the agencies allow banking
organizations to offset DTAs (net of
valuation allowance) and DTLs related
to a particular tax jurisdiction.
Moreover, for regulatory reporting
purposes, consistent with GAAP, the
agencies require separate calculations of
income taxes, both current and deferred
amounts, for each tax jurisdiction.
Accordingly, banking organizations
must calculate DTAs and DTLs on a
state-by-state basis for financial
reporting purposes under GAAP and for
regulatory reporting purposes.
with, a hedge fund or a private equity
fund.113
Section 13(d)(3) of the Bank Holding
Company Act provides that the relevant
agencies ‘‘shall . . . adopt rules
imposing additional capital
requirements and quantitative
limitations, including diversification
requirements, regarding activities
permitted under [Section 13] if the
appropriate Federal banking agencies,
the SEC, and the Commodity Futures
Trading Commission (CFTC) determine
that additional capital and quantitative
limitations are appropriate to protect the
safety and soundness of banking entities
engaged in such activities.’’ The DoddFrank Act also added section
13(d)(4)(B)(iii) to the Bank Holding
Company Act, which pertains to
investments in a hedge fund or private
equity fund organized and offered by a
banking entity and provides for
deductions from the assets and tangible
equity of the banking entity for these
investments in hedge funds or private
equity funds.
On November 7, 2011, the agencies,
the FDIC, and the SEC issued a proposal
to implement Section 13 of the Bank
Holding Company Act.114 The proposal
would require a ‘‘banking entity’’ to
deduct from tier 1 capital its
investments in a hedge fund or a private
equity fund that the banking entity
organizes and offers.115 The agencies
intend to address this capital
requirement, as it applies to banking
organizations, within the context of the
agencies’ entire regulatory capital
framework, so that its potential
interaction with all other regulatory
capital requirements can be fully
assessed.
3. Investments in Hedge Funds and
Private Equity Funds Pursuant to
Section 13 of the Bank Holding
Company Act
VI. Denominator Changes Related to the
Regulatory Capital Changes
Consistent with Basel III, the proposal
provided a 250 percent risk weight for
the portion of the following items that
are not otherwise subject to deduction:
(1) MSAs, (2) DTAs arising from
temporary differences that a banking
organization could not realize through
net operating loss carrybacks (net of any
related valuation allowances and net of
Section 13 of the Bank Holding
Company Act, which was added by
section 619 of the Dodd-Frank Act,
contains a number of restrictions and
other prudential requirements
applicable to any ‘‘banking entity’’ 112
that engages in proprietary trading or
has certain interests in, or relationships
112 See 12 U.S.C. 1851. The term ‘‘banking entity’’
is defined in section 13(h)(1) of the Bank Holding
Company Act, as amended by section 619 of the
Dodd-Frank Act. See 12 U.S.C. 1851(h)(1). The
statutory definition includes any insured depository
institution (other than certain limited purpose trust
institutions), any company that controls an insured
depository institution, any company that is treated
as a bank holding company for purposes of section
8 of the International Banking Act of 1978 (12
U.S.C. 3106), and any affiliate or subsidiary of any
of the foregoing.
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113 Section 13 of the Bank Holding Company Act
defines the terms ‘‘hedge fund’’ and ‘‘private equity
fund’’ as ‘‘an issuer that would be an investment
company, as defined in the Investment Company
Act of 1940, but for section 3(c)(1) or 3(c)(7) of that
Act, or such similar funds as the [relevant agencies]
may, by rule . . . determine.’’ See 12 U.S.C.
1851(h)(2).
114 See 76 FR 68846 (November 7, 2011). On
February 14, 2012, the CFTC published a
substantively similar proposed rule implementing
section 13 of the Bank Holding Company Act. See
77 FR 8332 (February 14, 2012).
115 See Id., § l.12(d).
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DTLs, as described in section 22(e) of
the rule), and (3) significant investments
in the capital of unconsolidated
financial institutions in the form of
common stock that are not deducted
from tier 1 capital.
Several commenters objected to the
proposed 250 percent risk weight and
stated that the agencies and the FDIC
instead should apply a 100 percent risk
weight to the amount of these assets
below the deduction thresholds.
Commenters stated that the relatively
high risk weight would drive business,
particularly mortgage servicing, out of
the banking sector and into unregulated
shadow banking entities.
After considering the comments, the
agencies continue to believe that the 250
percent risk weight is appropriate in
light of the relatively greater risks
inherent in these assets, as described
above. These risks are sufficiently
significant that concentrations in these
assets warrant deductions from capital,
and any exposure to these assets merits
a higher-than 100 percent risk weight.
Therefore, the final rule adopts the
proposed treatment without change.
The final rule, consistent with the
proposal, requires banking organizations
to apply a 1,250 percent risk weight to
certain exposures that were subject to
deduction under the general risk-based
capital rules. Therefore, for purposes of
calculating total risk-weighted assets,
the final rule requires a banking
organization to apply a 1,250 percent
risk weight to the portion of a creditenhancing interest-only strip (CEIO) that
does not constitute an after-tax-gain-onsale.
VII. Transition Provisions
The proposal established transition
provisions for: (i) Minimum regulatory
capital ratios; (ii) capital conservation
and countercyclical capital buffers; (iii)
regulatory capital adjustments and
deductions; (iv) non-qualifying capital
instruments; and (v) the supplementary
leverage ratio. Most of the transition
periods in the proposal began on
January 1, 2013, and would have
provided banking organizations between
three and six years to comply with the
requirements in the proposed rule.
Among other provisions, the proposal
would have provided a transition period
for the phase-out of non-qualifying
capital instruments from regulatory
capital under either a three- or ten-year
transition period based on the
organization’s consolidated total assets.
The proposed transition provisions were
designed to give banking organizations
sufficient time to adjust to the revised
capital framework while minimizing the
potential impact that implementation
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could have on their ability to lend. The
transition provisions also were designed
to ensure compliance with the DoddFrank Act. As a result, they would have
been, in certain circumstances, more
stringent than the transition
arrangements set forth in Basel III.
The agencies and the FDIC received
multiple comments on the proposed
transition framework. Most of the
commenters characterized the proposed
transition schedule for the minimum
capital ratios as overly aggressive and
expressed concern that banking
organizations would not be able to meet
the increased capital requirements (in
accordance with the transition
schedule) in the current economic
environment. Commenters representing
community banking organizations
argued that such organizations generally
have less access to the capital markets
relative to larger banking organizations
and, therefore, usually increase capital
primarily by accumulating retained
earnings. Accordingly, these
commenters requested additional time
to satisfy the minimum capital
requirements under the proposed rule,
and specifically asked the agencies and
the FDIC to provide banking
organizations until January 1, 2019 to
comply with the proposed minimum
capital requirements. Other commenters
commenting on behalf of community
banking organizations, however,
considered the transition period
reasonable. One commenter requested a
shorter implementation timeframe for
the largest banking organizations,
asserting that these organizations
already comply with the proposed
standards. Another commenter
suggested removing the transition
period and delaying the effective date
until the industry more fully recovers
from the recent crisis. According to this
commenter, the effective date should be
delayed to ensure that implementation
of the rule would not result in a
contraction in aggregate U.S. lending
capacity.
Several commenters representing
SLHCs asked the agencies and the FDIC
to delay implementation of the final rule
for such organizations until July 21,
2015. Banking organizations not
previously supervised by the Board,
including SLHCs, become subject to the
applicable requirements of section 171
on that date.116 Additionally, these
commenters expressed concern that
SLHCs would not be able to comply
with the new minimum capital
requirements before that date because
they were not previously subject to the
agencies’ risk-based capital framework.
116 12
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The commenters asserted that SLHCs
would therefore need additional time to
change their capital structure, balance
sheets, and internal systems to comply
with the proposal. These commenters
also noted that the Board provided a
three-year implementation period for
BHCs when the general risk-based
capital rules were initially adopted.
Commenters representing SLHCs with
substantial insurance activity also
requested additional time to comply
with the proposal because some of these
organizations currently operate under a
different accounting framework and
would require a longer period of time to
adapt their systems to the proposed
capital rules, which generally are based
on GAAP.
A number of commenters suggested
an effective date based on the
publication date of the final rule in the
Federal Register. According to the
commenters, such an approach would
provide banking organizations with
certainty regarding the effective date of
the final rule that would allow them to
plan for and implement any required
system and process changes. One
commenter requested simultaneous
implementation of all three proposals
because some elements of the
Standardized Approach NPR affect the
implementation of the Basel III NPR. A
number of commenters also requested
additional time to comply with the
proposed capital conservation buffer.
According to these commenters,
implementation of the capital
conservation buffer would make the
equity instruments of banking
organizations less attractive to potential
investors and could even encourage
divestment among existing
shareholders. Therefore, the
commenters maintained, the proposed
rule would require banking
organizations to raise capital by
accumulating retained earnings, and
doing so could take considerable time in
the current economic climate. For these
reasons, the commenters asked the
agencies and the FDIC to delay
implementation of the capital
conservation buffer for an additional
five years to provide banking
organizations sufficient time to increase
retained earnings without curtailing
lending activity. Other commenters
requested that the agencies and the
FDIC fully exempt banks with total
consolidated assets of $50 billion or less
from the capital conservation buffer,
further recommending that if the
agencies and the FDIC declined to make
this accommodation then the phase-in
period for the capital conservation
buffer should be extended by at least
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three years to January 1, 2022, to
provide community banking
organizations with enough time to meet
the new regulatory minimums.
A number of commenters noted that
Basel III phases in the deduction of
goodwill from 2014 to 2018, and
requested that the agencies and the
FDIC adopt this transition for goodwill
in the United States to prevent U.S.
institutions from being disadvantaged
relative to their global competitors.
Many commenters objected to the
proposed schedule for the phase out of
TruPS from tier 1 capital, particularly
for banking organizations with less than
$15 billion in total consolidated assets.
As discussed in more detail in section
V.A., the commenters requested that the
agencies and the FDIC grandfather
existing TruPS issued by depository
institution holding companies with less
than $15 billion and 2010 MHCs, as
permitted by section 171 of the DoddFrank Act. In general, these commenters
characterized TruPS as a relatively safe,
low-cost form of capital issued in full
compliance with regulatory
requirements that would be difficult for
smaller institutions to replace in the
current economic environment. Some
commenters requested that community
banking organizations be exempt from
the phase-out of TruPS and from the
phase-out of cumulative preferred stock
for these reasons. Another commenter
requested that the agencies and the
FDIC propose that institutions with
under $5 billion in total consolidated
assets be allowed to continue to include
TruPS in regulatory capital at full value
until the call or maturity of the TruPS
instrument.
Some commenters encouraged the
agencies and the FDIC to adopt the tenyear transition schedule under Basel III
for TruPS of banking organizations with
total consolidated assets of more than
$15 billion. These commenters asserted
that the proposed transition framework
for TruPS would disadvantage U.S.
banking organizations relative to foreign
competitors. One commenter expressed
concern that the transition framework
under the proposed rule also would
disrupt payment schedules for TruPS
CDOs.
Commenters proposed several
additional alternative transition
frameworks for TruPS. For example, one
commenter recommended a 10 percent
annual reduction in the amount of
TruPS banking organizations with $15
billion or more of total consolidated
assets may recognize in tier 1 capital
beginning in 2013, followed by a phaseout of the remaining amount in 2015.
According to the commenter, such a
framework would comply with the
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Dodd-Frank Act and allow banking
organizations more time to replace
TruPS. Another commenter suggested
that the final rule allow banking
organizations to progressively reduce
the amount of TruPS eligible for
inclusion in tier 1 capital by 1.25 to 2.5
percent per year. One commenter
encouraged the agencies and the FDIC to
avoid penalizing banking organizations
that elect to redeem TruPS during the
transition period. Specifically, the
commenter asked the agencies and the
FDIC to revise the proposed transition
framework so that any TruPS redeemed
during the transition period would not
reduce the total amount of TruPS
eligible for inclusion in tier 1 capital.
Under such an approach, the amount of
TruPS eligible for inclusion in tier 1
capital during the transition period
would equal the lesser of: (a) The
remaining outstanding balance or (b) the
percentage decline factor times the
balance outstanding at the time the final
rule is published in the Federal
Register.
One commenter encouraged the
agencies and the FDIC to allow a
banking organization that grows to more
than $15 billion in total assets as a
result of merger and acquisition activity
to remain subject to the proposed
transition framework for non-qualifying
capital instruments issued by
organizations with less than $15 billion
in total assets. According to the
commenter, such an approach should
apply to either the buyer or seller in the
transaction. Other commenters asked
the agencies and the FDIC to allow
banking organizations whose total
consolidated assets grew to over $15
billion just prior to May 19, 2010, and
whose asset base subsequently declined
below that amount to include all TruPS
in their tier 1 capital during 2013 and
2014 on the same basis as institutions
with less than $15 billion in total
consolidated assets and, thereafter, be
subject to the deductions required by
section 171 of the Dodd-Frank Act.
Commenters representing advanced
approaches banking organizations
generally objected to the proposed
transition framework for the
supplementary leverage ratio, and
requested a delay in its implementation.
For example, one commenter
recommended the agencies and the
FDIC defer implementation of the
supplementary leverage ratio until the
agencies and the FDIC have had an
opportunity to consider whether it is
likely to result in regulatory arbitrage
and international competitive inequality
as a result of differences in national
accounting frameworks and standards.
Another commenter asked the agencies
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and the FDIC to delay implementation
of the supplementary leverage ratio
until no earlier than January 1, 2018, as
provided in Basel III, or until the BCBS
completes its assessment and reaches
international agreement on any further
adjustments. A few commenters,
however, supported the proposed
transition framework for the
supplementary leverage ratio because it
could be used as an important
regulatory tool to ensure there is
sufficient capital in the financial
system.
After considering the comments and
the potential challenges some banking
organizations may face in complying
with the final rule, the agencies have
agreed to delay the compliance date for
banking organizations that are not
advanced approaches banking
organizations and for covered SLHCs
until January 1, 2015. Therefore, such
entities are not required to calculate
their regulatory capital requirements
under the final rule until January 1,
2015. Thereafter, these banking
organizations must calculate their
regulatory capital requirements in
accordance with the final rule, subject
to the transition provisions set forth in
subpart G of the final rule.
The final rule also establishes the
effective date of the final rule for
advanced approaches banking
organizations that are not SLHCs as
January 1, 2014. In accordance with
Tables 5–17 below, the transition
provisions for the regulatory capital
adjustments and deductions in the final
rule commence either one or two years
later than in the proposal, depending on
whether the banking organization is or
is not an advanced approaches banking
organization. The December 31, 2018,
end-date for the transition period for
regulatory capital adjustments and
deductions is the same under the final
rule as under the proposal.
A. Transitions Provisions for Minimum
Regulatory Capital Ratios
In response to the commenters’
concerns, the final rule modifies the
proposed transition provisions for the
minimum capital requirements. Banking
organizations that are not advanced
approaches banking organizations and
covered SLHCs are not required to
comply with the minimum capital
requirements until January 1, 2015. This
is a delay of two years from the
beginning of the proposed transition
period. Because the agencies are not
requiring compliance with the final rule
until January 1, 2015 for these entities,
there is no additional transition period
for the minimum regulatory capital
ratios. This approach should give
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banking organizations sufficient time to
raise or accumulate any additional
capital needed to satisfy the new
minimum requirements and upgrade
internal systems without adversely
affecting their lending capacity.
Under the final rule, an advanced
approaches banking organization that is
not an SLHC must comply with
minimum common equity tier 1, tier 1,
and total capital ratio requirements of
4.0 percent, 5.5 percent, and 8.0 percent
during calendar year 2014, and 4.5
percent, 6.0 percent, 8.0 percent,
respectively, beginning January 1, 2015.
These transition provisions are
consistent with those under Basel III for
internationally-active banking
organizations. During calendar year
2014, advanced approaches banking
organizations must calculate their
minimum common equity tier 1, tier 1,
and total capital ratios using the
definitions for the respective capital
components in section 20 of the final
rule (adjusted in accordance with the
transition provisions for regulatory
adjustments and deductions and for the
non-qualifying capital instruments for
advanced approaches banking
organizations described in this section).
B. Transition Provisions for Capital
Conservation and Countercyclical
Capital Buffers
The agencies have finalized
transitions for the capital conservation
and countercyclical capital buffers as
proposed. The capital conservation
buffer transition period begins in 2016,
a full year after banking organizations
that are not advanced approaches
banking organizations and banking
organizations that are covered SLHCs
are required to comply with the final
rule, and two years after advanced
approaches banking organizations that
are not SLHCs are required to comply
with the final rule. The agencies believe
that this is an adequate time frame to
meet the buffer level necessary to avoid
restrictions on capital distributions.
Table 5 shows the regulatory capital
levels advanced approaches banking
organizations that are not SLHCs
generally must satisfy to avoid
limitations on capital distributions and
discretionary bonus payments during
the applicable transition period, from
January 1, 2016 until January 1, 2019.
TABLE 5—REGULATORY CAPITAL LEVELS FOR ADVANCED APPROACHES BANKING ORGANIZATIONS
Jan. 1, 2014
(percent)
Capital conservation buffer ..............................................
Minimum common equity tier 1 capital ratio + capital
conservation buffer .......................................................
Minimum tier 1 capital ratio + capital conservation buffer
Minimum total capital ratio + capital conservation buffer
Maximum potential countercyclical capital buffer ............
Table 6 shows the regulatory capital
levels banking organizations that are not
advanced approaches banking
organizations and banking organizations
Jan. 1, 2015
(percent)
Jan. 1, 2016
(percent)
Jan. 1, 2017
(percent)
Jan. 1, 2018
(percent)
Jan. 1, 2019
(percent)
....................
....................
0.625
1.25
1.875
2.5
4.0
5.5
8.0
....................
4.5
6.0
8.0
....................
5.125
6.625
8.625
0.625
5.75
7.25
9.25
1.25
6.375
7.875
9.875
1.875
7.0
8.5
10.5
2.5
that are covered SLHCs generally must
satisfy to avoid limitations on capital
distributions and discretionary bonus
payments during the applicable
transition period, from January 1, 2016
until January 1, 2019.
TABLE 6—REGULATORY CAPITAL LEVELS FOR NON-ADVANCED APPROACHES BANKING ORGANIZATIONS
Jan. 1, 2015
(percent)
Capital conservation buffer ......................................................................
Minimum common equity tier 1 capital ratio + capital conservation buffer ..........................................................................................................
Minimum tier 1 capital ratio + capital conservation buffer ......................
Minimum total capital ratio + capital conservation buffer ........................
As provided in Table 5 and Table 6,
the transition period for the capital
conservation and countercyclical capital
buffers does not begin until January 1,
2016. During this transition period, from
January 1, 2016 through December 31,
Jan. 1, 2016
(percent)
Jan. 1, 2017
(percent)
Jan. 1, 2018
(percent)
Jan. 1, 2019
(percent)
....................
0.625
1.25
1.875
2.5
4.5
6.0
8.0
5.125
6.625
8.625
5.75
7.25
9.25
6.375
7.875
9.875
7.0
8.5
10.5
2018, all banking organizations are
subject to transition arrangements with
respect to the capital conservation
buffer as outlined in more detail in
Table 7. For advanced approaches
banking organizations, the
countercyclical capital buffer will be
phased in according to the transition
schedule set forth in Table 7 by
proportionately expanding each of the
quartiles of the capital conservation
buffer.
TABLE 7—TRANSITION PROVISION FOR THE CAPITAL CONSERVATION AND COUNTERCYCLICAL CAPITAL BUFFER
Maximum payout ratio (as a
percentage of eligible
retained income)
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Transition period
Capital conservation buffer
Calendar year 2016 .............
Greater than 0.625 percent (plus 25 percent of any applicable countercyclical capital buffer amount).
Less than or equal to 0.625 percent (plus 25 percent of any applicable countercyclical capital buffer amount), and greater than 0.469 percent (plus 18.75 percent of any applicable countercyclical capital buffer amount).
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TABLE 7—TRANSITION PROVISION FOR THE CAPITAL CONSERVATION AND COUNTERCYCLICAL CAPITAL BUFFER—
Continued
Transition period
Calendar year 2017 .............
Calendar year 2018 .............
Less than or equal to 0.469 percent (plus 18.75 percent of any applicable countercyclical capital buffer amount), and greater than 0.313 percent (plus 12.5 percent
of any applicable countercyclical capital buffer amount).
Less than or equal to 0.313 percent (plus 12.5 percent of any applicable countercyclical capital buffer amount), and greater than 0.156 percent (plus 6.25 percent
of any applicable countercyclical capital buffer amount).
Less than or equal to 0.156 percent (plus 6.25 percent of any applicable countercyclical capital buffer amount).
Greater than 1.25 percent (plus 50 percent of any applicable countercyclical capital
buffer amount).
Less than or equal to 1.25 percent (plus 50 percent of any applicable countercyclical capital buffer amount), and greater than 0.938 percent (plus 37.5 percent
of any applicable countercyclical capital buffer amount).
Less than or equal to 0.938 percent (plus 37.5 percent of any applicable countercyclical capital buffer amount), and greater than 0.625 percent (plus 25 percent
of any applicable countercyclical capital buffer amount).
Less than or equal to 0.625 percent (plus 25 percent of any applicable countercyclical capital buffer amount), and greater than 0.313 percent (plus 12.5 percent
of any applicable countercyclical capital buffer amount).
Less than or equal to 0.313 percent (plus 12.5 percent of any applicable countercyclical capital buffer amount).
Greater than 1.875 percent (plus 75 percent of any applicable countercyclical capital buffer amount).
Less than or equal to 1.875 percent (plus 75 percent of any applicable countercyclical capital buffer amount), and greater than 1.406 percent (plus 56.25 percent of any applicable countercyclical capital buffer amount).
Less than or equal to 1.406 percent (plus 56.25 percent of any applicable countercyclical capital buffer amount), and greater than 0.938 percent (plus 37.5 percent
of any applicable countercyclical capital buffer amount).
Less than or equal to 0.938 percent (plus 37.5 percent of any applicable countercyclical capital buffer amount), and greater than 0.469 percent (plus 18.75 percent of any applicable countercyclical capital buffer amount).
Less than or equal to 0.469 percent (plus 18.75 percent of any applicable countercyclical capital buffer amount).
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C. Transition Provisions for Regulatory
Capital Adjustments and Deductions
To give sufficient time to banking
organizations to adapt to the new
regulatory capital adjustments and
deductions, the final rule incorporates
transition provisions for such
adjustments and deductions that
commence at the time at which the
banking organization becomes subject to
the final rule. As explained above, the
final rule maintains the proposed
transition periods, except for nonqualifying capital instruments as
described below.
Banking organizations that are not
advanced approaches banking
organizations and banking organizations
that are covered SLHCs will begin the
transitions for regulatory capital
adjustments and deductions on January
1, 2015. From January 1, 2015, through
December 31, 2017, these banking
organizations will be required to make
the regulatory capital adjustments to
and deductions from regulatory capital
in section 22 of the final rule in
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Maximum payout ratio (as a
percentage of eligible
retained income)
Capital conservation buffer
Jkt 232001
accordance with the proposed transition
provisions for such adjustments and
deductions outlined below. Starting on
January 1, 2018, these banking
organizations will apply all regulatory
capital adjustments and deductions as
set forth in section 22 of the final rule.
For an advanced approaches banking
organization that is not an SLHC, the
first year of transition for adjustments
and deductions begins on January 1,
2014. From January 1, 2014, through
December 31, 2017, such banking
organizations will be required to make
the regulatory capital adjustments to
and deductions from regulatory capital
in section 22 of the final rule in
accordance with the proposed transition
provisions for such adjustments and
deductions outlined below. Starting on
January 1, 2018, advanced approaches
banking organizations will be subject to
all regulatory capital adjustments and
deductions as described in section 22 of
the final rule.
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40.
20.
0.
No payout ratio limitation
applies.
60.
40.
20.
0.
No payout ratio limitation
applies.
60.
40.
20.
0.
1. Deductions for Certain Items Under
Section 22(a) of the Final Rule
The final rule provides that banking
organizations will deduct from common
equity tier 1 capital or tier 1 capital in
accordance with Table 8 below: (1)
Goodwill (section 22(a)(1)); (2) DTAs
that arise from operating loss and tax
credit carryforwards (section 22(a)(3));
(3) gain-on-sale associated with a
securitization exposure (section
22(a)(4)): (4) defined benefit pension
fund assets (section 22(a)(5)); (5) for an
advanced approaches banking
organization that has completed the
parallel run process and that has
received notification from its primary
Federal supervisor pursuant to section
121(d) of subpart E of the final rule,
expected credit loss that exceeds
eligible credit reserves (section 22(a)(6));
and (6) financial subsidiaries (section
22(a)(7)). During the transition period,
the percentage of these items that is not
deducted from common equity tier 1
capital must be deducted from tier 1
capital.
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62077
TABLE 8—TRANSITION DEDUCTIONS UNDER SECTION 22(a)(1) AND SECTIONS 22(a)(3)–(a)(7) OF THE FINAL RULE
Transition deductions under sections
22(a)(3)–(a)(6)
Transition
deductions under
section 22(a)(1)
and (7) 1
Percentage of the
deductions from
common equity
tier 1 capital
Transition period
Percentage of the
deductions from
common equity
tier 1 capital
January 1, 2014 to December 31, 2014 (advanced approaches banking organizations only) ...............................................................................................................
January 1, 2015 to December 31, 2015 ...................................................................
January 1, 2016 to December 31, 2016 ...................................................................
January 1, 2017 to December 31, 2017 ...................................................................
January 1, 2018 and thereafter .................................................................................
1 In
Percentage of the
deductions from
tier 1 capital
20
40
60
80
100
80
60
40
20
0
100
100
100
100
100
addition, a FSA should deduct from common equity tier 1 non-includable subsidiaries. See 12 CFR 3.22(a)(8).
Beginning on January 1, 2014,
advanced approaches banking
organizations that are not SLHCs will be
required to deduct the full amount of
goodwill (which may be net of any
associated DTLs), including any
goodwill embedded in the valuation of
significant investments in the capital of
unconsolidated financial institutions,
from common equity tier 1 capital. All
other banking organizations will begin
deducting goodwill (which may be net
of any associated DTLs), including any
goodwill embedded in the valuation of
significant investments in the capital of
unconsolidated financial institutions
from common equity tier 1 capital, on
January 1, 2015. This approach is
stricter than the Basel III approach,
which transitions the goodwill
deduction from common equity tier 1
capital through 2017. However, as
discussed in section V.B of this
preamble, under U.S. law, goodwill
cannot be included in a banking
organization’s regulatory capital and has
not been included in banking
organizations’ regulatory capital under
the general risk-based capital rules.117
Additionally, the agencies believe that
fully deducting goodwill from common
equity tier 1 capital from the date a
banking organization must comply with
the final rule will result in a more
appropriate measure of common equity
tier 1 capital.
Beginning on January 1, 2014, a
national bank or insured state bank
subject to the advanced approaches rule
will be required to deduct 100 percent
of the aggregate amount of its
outstanding equity investment,
including the retained earnings, in any
financial subsidiary from common
equity tier 1 capital. All other national
and insured state banks will begin
deducting 100 percent of the aggregate
amount of their outstanding equity
investment, including the retained
earnings, in a financial subsidiary from
common equity tier 1 capital on January
1, 2015. The deduction from common
equity tier 1 capital represents a change
from the general risk-based capital rules,
which require the deduction to be made
from total capital. As explained in
section V.B of this preamble, similar to
goodwill, this deduction is required by
statute and is consistent with the
general risk-based capital rules.
Accordingly, the deduction is not
subject to a transition period.
The final rule also retains the existing
deduction for Federal associations’
investments in, and extensions of credit
to, non-includable subsidiaries at 12
CFR 3.22(a)(8).118 This deduction is
required by statute 119 and is consistent
with the general risk-based capital rules.
Accordingly, the deduction is not
subject to a transition period and must
be fully deducted in the first year that
the Federal or state savings association
becomes subject to the final rule.
2. Deductions for Intangibles Other
Than Goodwill and Mortgage Servicing
Assets
For deductions of intangibles other
than goodwill and MSAs, including
purchased credit-card relationships
(PCCRs) (see section 22(a)(2) of the final
rule), the applicable transition period in
the final rule is set forth in Table 9.
During the transition period, any of
these items that are not deducted will be
subject to a risk weight of 100 percent.
Advanced approaches banking
organizations that are not SLHCs will
begin the transition on January 1, 2014,
and other banking organizations will
begin the transition on January 1, 2015.
TABLE 9—TRANSITION DEDUCTIONS UNDER SECTION 22(a)(2) OF THE PROPOSAL
Transition deductions under section
22(a)(2)—Percentage of the deductions
from common equity tier 1 capital
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Transition period
January
January
January
January
January
1,
1,
1,
1,
1,
2014
2015
2016
2017
2018
to December 31, 2014 (advanced approaches banking organizations only) ..........
to December 31, 2015 .............................................................................................
to December 31, 2016 .............................................................................................
to December 31, 2017 .............................................................................................
and thereafter ...........................................................................................................
117 See 12 U.S.C. 1464(t)(9)(A) and 12 U.S.C.
1828(n).
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118 For additional information on this deduction,
see section V.B ‘‘Activities by savings association
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20
40
60
80
100
subsidiaries that are impermissible for national
banks’’ of this preamble.
119 See 12 U.S.C. 1464(t)(5).
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3. Regulatory Adjustments Under
Section 22(b)(1) of the Final Rule
During the transition period, any of
the adjustments required under section
22(b)(1) that are not applied to common
equity tier 1 capital must be applied to
tier 1 capital instead, in accordance
with Table 10. Advanced approaches
banking organizations that are not
SLHCs will begin the transition on
January 1, 2014, and other banking
organizations will begin the transition
on January 1, 2015.
TABLE 10—TRANSITION ADJUSTMENTS UNDER SECTION 22(b)(1)
Transition adjustments under section 22(b)(1)
Transition period
Percentage of the adjustment
applied to common equity tier 1
capital
Percentage of the adjustment
applied to tier 1 capital
20
40
60
80
100
80
60
40
20
0
January 1, 2014, to December 31, 2014 (advanced approaches
banking organizations only) .........................................................
January 1, 2015, to December 31, 2015 ........................................
January 1, 2016, to December 31, 2016 ........................................
January 1, 2017, to December 31, 2017 ........................................
January 1, 2018 and thereafter .......................................................
4. Phase-out of Current Accumulated
Other Comprehensive Income
Regulatory Capital Adjustments
Under the final rule, the transition
period for the inclusion of the aggregate
amount of: (1) Unrealized gains on
available-for-sale equity securities; (2)
net unrealized gains or losses on
available-for-sale debt securities; (3) any
amounts recorded in AOCI attributed to
defined benefit postretirement plans
resulting from the initial and
subsequent application of the relevant
GAAP standards that pertain to such
plans (excluding, at the banking
organization’s option, the portion
relating to pension assets deducted
under section 22(a)(5)); (4) accumulated
net gains or losses on cash-flow hedges
related to items that are reported on the
balance sheet at fair value included in
AOCI; and (5) net unrealized gains or
losses on held-to-maturity securities
that are included in AOCI (transition
AOCI adjustment amount) only applies
to advanced approaches banking
organizations and other banking
organizations that have not made an
AOCI opt-out election under section
22(b)(2) of the rule and described in
section V.B of this preamble. Advanced
approaches banking organizations that
are not SLHCs will begin the phase out
of the current AOCI regulatory capital
adjustments on January 1, 2014; other
banking organizations that have not
made the AOCI opt-out election will
begin making these adjustments on
January 1, 2015. Specifically, if a
banking organization’s transition AOCI
adjustment amount is positive, it will
adjust its common equity tier 1 capital
by deducting the appropriate percentage
of such aggregate amount in accordance
with Table 11 below. If such amount is
negative, it will adjust its common
equity tier 1 capital by adding back the
appropriate percentage of such aggregate
amount in accordance with Table 11
below. The agencies and the FDIC did
not include net unrealized gains or
losses on held-to-maturity securities
that are included in AOCI as part of the
transition AOCI adjustment amount in
the proposal. However, the agencies
have decided to add such an adjustment
as it reflects the agencies’ approach
towards AOCI adjustments in the
general risk: Based capital rules.
TABLE 11—PERCENTAGE OF THE TRANSITION AOCI ADJUSTMENT AMOUNT
Percentage of the transition AOCI
adjustment amount to be applied to common
equity tier 1 capital
Transition period
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January 1, 2014, to December 31, 2014 (advanced approaches banking organizations only) .........
January 1, 2015, to December 31, 2015 (advanced approaches banking organizations and banking organizations that have not made an opt-out election) .............................................................
January 1, 2016, to December 31, 2016 (advanced approaches banking organizations and banking organizations that have not made an opt-out election) .............................................................
January 1, 2017, to December 31, 2017 (advanced approaches banking organizations and banking organizations that have not made an opt-out election) .............................................................
January 1, 2018 and thereafter (advanced approaches banking organizations and banking organizations that have not made an opt-out election) .............................................................................
Beginning on January 1, 2018,
advanced approaches banking
organizations and other banking
organizations that have not made an
AOCI opt-out election must include
AOCI in common equity tier 1 capital,
with the exception of accumulated net
gains and losses on cash-flow hedges
related to items that are not measured at
fair value on the balance sheet, which
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must be excluded from common equity
tier 1 capital.
5. Phase-Out of Unrealized Gains on
Available for Sale Equity Securities in
Tier 2 Capital
Advanced approaches banking
organizations and banking organizations
not subject to the advanced approaches
rule that have not made an AOCI optout election will decrease the amount of
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80
60
40
20
0
unrealized gains on AFS preferred stock
classified as an equity security under
GAAP and AFS equity exposures
currently held in tier 2 capital during
the transition period in accordance with
Table 12. An advanced approaches
banking organization that is not an
SLHC will begin the adjustments on
January 1, 2014; all other banking
organizations that have not made an
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62079
AOCI opt-out election will begin the
adjustments on January 1, 2015.
TABLE 12—PERCENTAGE OF UNREALIZED GAINS ON AFS PREFERRED STOCK CLASSIFIED AS AN EQUITY SECURITY
UNDER GAAP AND AFS EQUITY EXPOSURES THAT MAY BE INCLUDED IN TIER 2 CAPITAL
Percentage of unrealized gains on AFS
preferred stock classified as an equity
security under GAAP and AFS equity
exposures that may be included in tier 2
capital
Transition period
January 1, 2014, to December 31, 2014 (advanced approaches banking organizations only) .........
January 1, 2015, to December 31, 2015 (advanced approaches banking organizations and banking organizations that have not made an opt-out election) .............................................................
January 1, 2016, to December 31, 2016 (advanced approaches banking organizations and banking organizations that have not made an opt-out election) .............................................................
January 1, 2017, to December 31, 2017 (advanced approaches banking organizations and banking organizations that have not made an opt-out election) .............................................................
January 1, 2018 and thereafter (advanced approaches banking organizations and banking organizations that have not made an opt-out election) .............................................................................
6. Phase-in of Deductions Related to
Investments in Capital Instruments and
to the Items Subject to the 10 and 15
Percent Common Equity Tier 1 Capital
Deduction Thresholds (Sections 22(c)
and 22(d)) of the Final Rule
Under the final rule, a banking
organization must calculate the
appropriate deductions under sections
22(c) and 22(d) of the rule related to
investments in the capital of
unconsolidated financial institutions
and to the items subject to the 10 and
15 percent common equity tier 1 capital
deduction thresholds (that is, MSAs,
DTAs arising from temporary
differences that the banking
organization could not realize through
net operating loss carrybacks, and
significant investments in the capital of
unconsolidated financial institutions in
the form of common stock) as set forth
in Table 13. Advanced approaches
banking organizations that are not
SLHCs will apply the transition
framework beginning January 1, 2014.
All other banking organizations will
begin applying the transition framework
on January 1, 2015. During the
transition period, a banking
36
27
18
9
0
organization will make the aggregate
common equity tier 1 capital deductions
related to these items in accordance
with the percentages outlined in Table
13 and must apply a 100 percent riskweight to the aggregate amount of such
items that is not deducted. On January
1, 2018, and thereafter, each banking
organization will be required to apply a
250 percent risk weight to the aggregate
amount of the items subject to the 10
and 15 percent common equity tier 1
capital deduction thresholds that are not
deducted from common equity tier 1
capital.
TABLE 13—TRANSITION DEDUCTIONS UNDER SECTIONS 22(c) AND 22(d) OF THE PROPOSAL
Transition deductions under sections 22(c)
and 22(d)—Percentage of the deductions
from common equity tier 1 capital
January 1, 2014, to December 31, 2014 ............................................................................................
(advanced approaches banking organizations only) ...........................................................................
January 1, 2015, to December 31, 2015 ............................................................................................
January 1, 2016, to December 31, 2016 ............................................................................................
January 1, 2017, to December 31, 2017 ............................................................................................
January 1, 2018 and thereafter ...........................................................................................................
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Transition period
20
40
60
80
100
During the transition period, banking
organizations will phase in the
deduction requirement for the amounts
of DTAs arising from temporary
differences that could not be realized
through net operating loss carryback,
MSAs, and significant investments in
the capital of unconsolidated financial
institutions in the form of common
stock that exceed the 10 percent
threshold in section 22(d) according to
Table 13.
During the transition period, banking
organizations will not be subject to the
methodology to calculate the 15 percent
common equity deduction threshold for
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DTAs arising from temporary
differences that could not be realized
through net operating loss carrybacks,
MSAs, and significant investments in
the capital of unconsolidated financial
institutions in the form of common
stock described in section 22(d) of the
final rule. During the transition period,
a banking organization will be required
to deduct from its common equity tier
1 capital the percentage as set forth in
Table 13 of the amount by which the
aggregate sum of the items subject to the
10 and 15 percent common equity tier
1 capital deduction thresholds exceeds
15 percent of the sum of the banking
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organization’s common equity tier 1
capital after making the deductions and
adjustments required under sections
22(a) through (c).
D. Transition Provisions for NonQualifying Capital Instruments
Under the final rule, there are
different transition provisions for nonqualifying capital instruments
depending on the type and size of a
banking organization as discussed
below.
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1. Depository Institution Holding
Companies With Less than $15 Billion
in Total Consolidated Assets as of
December 31, 2009 and 2010 Mutual
Holding Companies
BHCs have historically included
(subject to limits) in tier 1 capital
‘‘restricted core capital elements’’ such
as cumulative perpetual preferred stock
and TruPS, which generally would not
comply with the eligibility criteria for
additional tier 1 capital instruments
outlined in section 20 of the final rule.
As discussed in section V.A of this
preamble, section 171 of the DoddFrank Act would not require depository
institution holding companies with less
than $15 billion in total consolidated
assets as of December 31, 2009,
(depository institution holding
companies under $15 billion) or 2010
MHCs to deduct these types of
instruments from tier 1 capital.
However, as discussed in section V.A of
this preamble, above, because these
instruments would no longer qualify as
tier 1 capital under the proposed criteria
and have been found to be less able to
absorb losses, the agencies and the FDIC
proposed to require depository
institution holding companies under
$15 billion and 2010 MHCs to phase
these instruments out of capital over a
10-year period consistent with Basel III.
For the reasons discussed in section
V.A of this preamble, as permitted by
section 171 of the Dodd-Frank Act, the
agencies have decided not to adopt this
proposal in the final rule. Depository
institution holding companies under
$15 billion and 2010 MHCs may
continue to include non-qualifying
instruments that were issued prior to
May 19, 2010 in tier 1 or tier 2 capital
in accordance with the general riskbased capital rules, subject to specific
limitations. More specifically, these
depository institution holding
companies will be able to continue
including outstanding tier 1 capital nonqualifying capital instruments in
additional tier 1 capital (subject to the
limit of 25 percent of tier 1 capital
elements excluding any non-qualifying
capital instruments and after all
regulatory capital deductions and
adjustments applied to tier 1 capital)
until they redeem the instruments or
until the instruments mature. Likewise,
consistent with the general risk-based
capital rules, any tier 1 capital
instrument that is excluded from tier 1
because it exceeds the 25 percent limit
referenced above can be included in tier
2 capital.120
2. Depository Institutions
Under the final rule, beginning on
January 1, 2014, an advanced
approaches depository institution and
beginning on January 1, 2015, a
depository institution that is not a
depository institution subject to the
advanced approaches rule may include
in regulatory capital debt or equity
instruments issued prior to September
12, 2010 that do not meet the criteria for
additional tier 1 or tier 2 capital
instruments in section 20 of the final
rule, but that were included in tier 1 or
tier 2 capital, respectively, as of
September 12, 2010 (non-qualifying
capital instruments issued prior to
September 12, 2010). These instruments
may be included up to the percentage of
the outstanding principal amount of
such non-qualifying capital instruments
as of the effective date of the final rule
in accordance with the phase-out
schedule in Table 14.
As of January 1, 2014 for advanced
approaches banking organizations that
are not SLHCs, and January 1, 2015 for
all other banking organizations and for
covered SLHCs that are advanced
approaches organizations, debt or equity
instruments issued after September 12,
2010, that do not meet the criteria for
additional tier 1 or tier 2 capital
instruments in section 20 of the final
rule may not be included in additional
tier 1 or tier 2 capital.
TABLE 14—PERCENTAGE OF NON-QUALIFYING CAPITAL INSTRUMENTS ISSUED PRIOR TO SEPTEMBER 12, 2010
INCLUDABLE IN ADDITIONAL TIER 1 OR TIER 2 CAPITAL
Percentage of non-qualifying capital
instruments issued prior to September 2010
includable in additional tier 1 or tier 2 capital
for depository institutions
Transition Period (calendar year)
Calendar
Calendar
Calendar
Calendar
Calendar
Calendar
Calendar
Calendar
Calendar
year
year
year
year
year
year
year
year
year
2014
2015
2016
2017
2018
2019
2020
2021
2022
(advanced approaches banking organizations only) ..........................................
.............................................................................................................................
.............................................................................................................................
.............................................................................................................................
.............................................................................................................................
.............................................................................................................................
.............................................................................................................................
.............................................................................................................................
and thereafter .....................................................................................................
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3. Depository Institution Holding
Companies With $15 Billion or More in
Total Consolidated Assets as of
December 31, 2009 That Are Not 2010
Mutual Holding Companies
Under the final rule, consistent with
the proposal and with section 171 of the
Dodd-Frank Act, debt or equity
instruments that do not meet the criteria
for additional tier 1 or tier 2 capital
instruments in section 20 of the final
120 12
CFR part 225, appendix A, 1(b)(3).
with the language of the statute,
this requirement also applies to those institutions
121 Consistent
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80
70
60
50
40
30
20
10
0
rule, but that were issued and included
in tier 1 or tier 2 capital, respectively,
prior to May 19, 2010 (non-qualifying
capital instruments) and were issued by
a depository institution holding
company with total consolidated assets
greater than or equal to $15 billion as of
December 31, 2009 (depository
institution holding company of $15
billion or more) that is not a 2010 MHC
must be phased out as set forth in Table
15 below.121 More specifically,
depository institution holding
companies of $15 billion or more that
are advanced approaches banking
organizations and that are not SLHCs
must begin to apply this phase-out on
January 1, 2014; other depository
institution holding companies of $15
billion or more, including covered
SLHCs, must begin to apply the phaseout on January 1, 2015. Accordingly,
that, for a brief period of time, exceeded the $15
billion threshold and then subsequently have fallen
below it so long as their asset size was greater than
or equal to $15 billion in total consolidated assets
as of December 31, 2009.
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under the final rule, a depository
institution holding company of $15
billion or more that is an advanced
approaches banking organization and
that is not an SLHC will be allowed to
include only 50 percent of nonqualifying capital instruments in
regulatory capital as of January 1, 2014;
all depository institution holding
companies of $15 billion or more will be
allowed to include only 25 percent as of
January 1, 2015, and 0 percent as of
January 1, 2016, and thereafter.
The agencies acknowledge that the
majority of existing TruPS would not
technically comply with the final rule’s
tier 2 capital eligibility criteria (given
that existing TruPS allow for
acceleration after 5 years of interest
deferral) even though these instruments
are eligible for inclusion in tier 2 capital
under the general risk-based capital
rules. However, the agencies believe
that: (1) The inclusion of existing TruPS
in tier 2 capital (until they are redeemed
or they mature) does not raise safety and
soundness concerns, and (2) it may be
less disruptive to the banking system to
allow certain banking organizations to
include TruPS in tier 2 capital until
they are able to replace such
instruments with new capital
instruments that fully comply with the
eligibility criteria of the final rule.
Accordingly, the agencies have decided
to permit non-advanced approaches
depository institution holding
companies with over $15 billion in total
consolidated assets permanently to
include non-qualifying capital
instruments, including TruPS that are
phased out of tier 1 capital in tier 2
capital and not phase-out those
instruments.
Under the final rule, advanced
approaches depository institution
holding companies will not be
permitted to permanently include
62081
existing non-qualifying capital
instruments in tier 2 capital if they do
not meet tier 2 criteria under the final
rule. Such banking organizations
generally face fewer market obstacles in
replacing non-qualifying capital
instruments than smaller banking
organizations. From January 1, 2016,
until December 31, 2021, these banking
organizations will be required to phase
out non-qualifying capital instruments
from tier 2 capital in accordance with
the percentages in Table 14 above.
Consequently, an advanced approaches
depository institution holding company
will be allowed to include in tier 2
capital in calendar year 2016 up to 60
percent of the principal amount of
TruPS that such banking organization
had outstanding as of January 1, 2014,
but will not be able to include any of
these instruments in regulatory capital
after year-end 2021.
TABLE 15—PERCENTAGE OF NON-QUALIFYING CAPITAL INSTRUMENTS INCLUDABLE IN ADDITIONAL TIER 1 OR TIER 2
CAPITAL
Percentage of non-qualifying capital
instruments includable in additional tier 1 or
tier 2 capital for depository institution holding
companies of $15 billion or more
Calendar year 2014 (advanced approaches banking organizations only) ..........................................
Calendar year 2015 .............................................................................................................................
Calendar year 2016 And thereafter .....................................................................................................
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Transition period (calendar year)
50
25
0
4. Merger and Acquisition Transition
Provisions
Under the final rule, consistent with
the proposal, if a depository institution
holding company of $15 billion or more
acquires a depository institution
holding company with total
consolidated assets of less than $15
billion as of December 31, 2009 or a
2010 MHC, the non-qualifying capital
instruments of the resulting
organization will be subject to the
phase-out schedule outlined in Table
15, above. Likewise, if a depository
institution holding company under $15
billion makes an acquisition and the
resulting organization has total
consolidated assets of $15 billion or
more, its non-qualifying capital
instruments also will be subject to the
phase-out schedule outlined in Table
15, above. Some commenters argued
that this provision could create
disincentives for mergers and
acquisitions, but the agencies continue
to believe these provisions
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appropriately subject institutions that
are larger (or that become larger) to the
stricter phase-out requirements for nonqualifying capital instruments,
consistent with the language and intent
of section 171 of the Dodd-Frank Act.
Depository institution holding
companies under $15 billion and 2010
MHCs that merge with or acquire other
banking organizations that result in
organizations that remain below $15
billion or remain MHCs would be able
to continue to include non-qualifying
capital instruments in regulatory
capital.
5. Phase-Out Schedule for Surplus and
Non-Qualifying Minority Interest
Under the transition provisions in the
final rule, a banking organization is
allowed to include in regulatory capital
a portion of the common equity tier 1,
tier 1, or total capital minority interest
that is disqualified from regulatory
capital as a result of the requirements
and limitations outlined in section 21
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(surplus minority interest). If a banking
organization has surplus minority
interest outstanding when the final rule
becomes effective, that surplus minority
interest will be subject to the phase-out
schedule outlined in Table 16.
Advanced approaches banking
organizations that are not SLHCs must
begin to phase out surplus minority
interest in accordance with Table 16
beginning on January 1, 2014. All other
banking organizations will begin the
phase out for surplus minority interest
on January 1, 2015.
During the transition period, a
banking organization will also be able to
include in tier 1 or total capital a
portion of the instruments issued by a
consolidated subsidiary that qualified as
tier 1 or total capital of the banking
organization on the date the rule
becomes effective, but that do not
qualify as tier 1 or total capital under
section 20 of the final rule (nonqualifying minority interest) in
accordance with Table 16.
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TABLE 16 —PERCENTAGE OF THE AMOUNT OF SURPLUS OR NON-QUALIFYING MINORITY INTEREST INCLUDABLE IN
REGULATORY CAPITAL DURING TRANSITION PERIOD
Percentage of the amount of surplus or
non-qualifying minority interest that can be
included in regulatory capital during the
transition period
Transition period
January
January
January
January
January
1,
1,
1,
1,
1,
2014, to December 31, 2014 (advanced approaches banking organizations only) .........
2015, to December 31, 2015 ............................................................................................
2016, to December 31, 2016 ............................................................................................
2017, to December 31, 2017 ............................................................................................
2018 and thereafter ...........................................................................................................
VIII. Standardized Approach for RiskWeighted Assets
In the Standardized Approach NPR,
the agencies and the FDIC proposed to
revise methodologies for calculating
risk-weighted assets. As discussed
above and in the proposal, these
revisions were intended to harmonize
the agencies’ and the FDIC’s rules for
calculating risk-weighted assets and to
enhance the risk sensitivity and
remediate weaknesses identified over
recent years.122 The proposed revisions
incorporated elements of the Basel II
standardized approach 123 as modified
by the 2009 Enhancements, certain
aspects of Basel III, and other proposals
in recent consultative papers published
by the BCBS.124 Consistent with section
939A of the Dodd-Frank Act, the
agencies and the FDIC also proposed
alternatives to credit ratings for
calculating risk weights for certain
assets.
The proposal also included potential
revisions for the recognition of credit
risk mitigation that would allow for
greater recognition of financial collateral
and a wider range of eligible guarantors.
In addition, the proposal set forth more
risk-sensitive treatments for residential
mortgages, equity exposures and past
due loans, derivatives and repo-style
transactions cleared through CCPs, and
certain commercial real estate exposures
that typically have higher credit risk, as
well as operational requirements for
securitization exposures. The agencies
and the FDIC also proposed to apply
disclosure requirements to top-tier
banking organizations with $50 billion
122 77
FR 52888 (August 30, 2012).
BCBS, ‘‘International Convergence of
Capital Measurement and Capital Standards: A
Revised Framework,’’ (June 2006), available at
https://www.bis.org/publ/bcbs128.htm.
124 See, e.g., ‘‘Basel III FAQs answered by the
Basel Committee’’ (July, October, December 2011),
available at https://www.bis.org/list/press_releases/
index.htm; ‘‘Capitalization of Banking Organization
Exposures to Central Counterparties’’ (December
2010, revised November 2011) (CCP consultative
release), available at https://www.bis.org/publ/
bcbs206.pdf.
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123 See
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or more in total assets that are not
subject to the advanced approaches rule.
The agencies and the FDIC received a
significant number of comments
regarding the proposed standardized
approach for risk-weighted assets.
Although a few commenters observed
that the proposals would provide a
sound framework for determining riskweighted assets for all banking
organizations that would generally
benefit U.S. banking organizations, a
significant number of other commenters
asserted that the proposals were too
complex and burdensome, especially for
smaller banking organizations, and
some argued that it was inappropriate to
apply the proposed requirements to
such banking organizations because
such institutions did not cause the
recent financial crisis. Other
commenters expressed concern that the
new calculation for risk-weighted assets
would adversely affect banking
organizations’ regulatory capital ratios
and that smaller banking organizations
would have difficulties obtaining the
data and performing the calculations
required by the proposals. A number of
commenters also expressed concern
about the burden of the proposals in the
context of multiple new regulations,
including new standards for mortgages
and increased regulatory capital
requirements generally. One commenter
urged the agencies and the FDIC to
maintain key aspects of the proposed
risk-weighted asset treatment for
community banking organizations, but
generally requested that the agencies
and the FDIC reduce the perceived
complexity. The agencies have
considered these comments and, where
applicable, have focused on simplicity,
comparability, and broad applicability
of methodologies for U.S. banking
organizations under the standardized
approach.
Some commenters asked that the
proposed requirements be optional for
community banking organizations until
the effects of the proposals have been
studied, or that the proposed
standardized approach be withdrawn
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80
60
40
20
0
entirely. A number of the commenters
requested specific modifications to the
proposals. For example, some requested
an exemption for community banking
organizations from the proposed due
diligence requirements for securitization
exposures. Other commenters requested
that the agencies and the FDIC
grandfather the risk weighting of
existing loans, arguing that doing so
would lessen the proposed rule’s
implementation burden.
To address commenters’ concerns
about the standardized approach’s
burden and the accessibility of credit,
the agencies have revised elements of
the proposed rule, as described in
further detail below. In particular, the
agencies have modified the proposed
approach to risk weighting residential
mortgage loans to reflect the approach
in the agencies general risk-based
capital rules. The agencies believe the
standardized approach more accurately
captures the risk of banking
organizations’ assets and, therefore, are
applying this aspect of the final rule to
all banking organizations subject to the
rule.
This section of the preamble describes
in detail the specific proposals for the
standardized treatment of risk-weighted
assets, comments received on those
proposals, and the provisions of the
final rule in subpart D as adopted by the
agencies. These sections of the preamble
discuss how subpart D of the final rule
differs from the general risk-based
capital rules, and provides examples for
how a banking organization must
calculate risk-weighted asset amounts
under the final rule.
Beginning on January 1, 2015, all
banking organizations will be required
to calculate risk-weighted assets under
subpart D of the final rule. Until then,
banking organizations must calculate
risk-weighted assets using the
methodologies set forth in the general
risk-based capital rules. Advanced
approaches banking organizations are
subject to additional requirements, as
described in section III.D of this
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preamble, regarding the timeframe for
implementation.
A. Calculation of Standardized Total
Risk-Weighted Assets
Consistent with the Standardized
Approach NPR, the final rule requires a
banking organization to calculate its
risk-weighted asset amounts for its onand off-balance sheet exposures and, for
market risk banks only, standardized
market risk-weighted assets as
determined under subpart F.125 Riskweighted asset amounts generally are
determined by assigning on-balance
sheet assets to broad risk-weight
categories according to the counterparty,
or, if relevant, the guarantor or
collateral. Similarly, risk-weighted asset
amounts for off-balance sheet items are
calculated using a two-step process: (1)
Multiplying the amount of the offbalance sheet exposure by a credit
conversion factor (CCF) to determine a
credit equivalent amount, and (2)
assigning the credit equivalent amount
to a relevant risk-weight category.
A banking organization must
determine its standardized total riskweighted assets by calculating the sum
of (1) its risk-weighted assets for general
credit risk, cleared transactions, default
fund contributions, unsettled
transactions, securitization exposures,
and equity exposures, each as defined
below, plus (2) market risk-weighted
assets, if applicable, minus (3) the
amount of the banking organization’s
ALLL that is not included in tier 2
capital, and any amounts of allocated
transfer risk reserves.
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B. Risk-Weighted Assets for General
Credit Risk
Consistent with the proposal, under
the final rule total risk-weighted assets
for general credit risk equals the sum of
the risk-weighted asset amounts as
calculated under section 31(a) of the
final rule. General credit risk exposures
include a banking organization’s onbalance sheet exposures (other than
cleared transactions, default fund
contributions to CCPs, securitization
exposures, and equity exposures, each
as defined in section 2 of the final rule),
exposures to over-the-counter (OTC)
derivative contracts, off-balance sheet
commitments, trade and transactionrelated contingencies, guarantees, repostyle transactions, financial standby
letters of credit, forward agreements, or
other similar transactions.
Under the final rule, the exposure
amount for the on-balance sheet
125 This final rule incorporates the market risk
rule into the integrated regulatory framework as
subpart F.
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component of an exposure is generally
the banking organization’s carrying
value for the exposure as determined
under GAAP. The agencies believe that
using GAAP to determine the amount
and nature of an exposure provides a
consistent framework that can be easily
applied across all banking
organizations. Generally, banking
organizations already use GAAP to
prepare their financial statements and
regulatory reports, and this treatment
reduces potential burden that could
otherwise result from requiring banking
organizations to comply with a separate
set of accounting and measurement
standards for risk-based capital
calculation purposes under non-GAAP
standards, such as regulatory accounting
practices or legal classification
standards.
For purposes of the definition of
exposure amount for AFS or held-tomaturity debt securities and AFS
preferred stock not classified as equity
under GAAP that are held by a banking
organization that has made an AOCI
opt-out election, the exposure amount is
the banking organization’s carrying
value (including net accrued but unpaid
interest and fees) for the exposure, less
any net unrealized gains, and plus any
net unrealized losses. For purposes of
the definition of exposure amount for
AFS preferred stock classified as an
equity security under GAAP that is held
by a banking organization that has made
an AOCI opt-out election, the exposure
amount is the banking organization’s
carrying value (including net accrued
but unpaid interest and fees) for the
exposure, less any net unrealized gains
that are reflected in such carrying value
but excluded from the banking
organization’s regulatory capital.
In most cases, the exposure amount
for an off-balance sheet component of an
exposure is determined by multiplying
the notional amount of the off-balance
sheet component by the appropriate
CCF as determined under section 33 of
the final rule. The exposure amount for
an OTC derivative contract or cleared
transaction is determined under
sections 34 and 35, respectively, of the
final rule, whereas exposure amounts
for collateralized OTC derivative
contracts, collateralized cleared
transactions, repo-style transactions,
and eligible margin loans are
determined under section 37 of the final
rule.
1. Exposures to Sovereigns
Consistent with the proposal, the final
rule defines a sovereign as a central
government (including the U.S.
government) or an agency, department,
ministry, or central bank of a central
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government. In the Standardized
Approach NPR, the agencies and the
FDIC proposed to retain the general riskbased capital rules’ risk weights for
exposures to and claims directly and
unconditionally guaranteed by the U.S.
government or its agencies. The final
rule adopts the proposed treatment and
provides that exposures to the U.S.
government, its central bank, or a U.S.
government agency and the portion of
an exposure that is directly and
unconditionally guaranteed by the U.S.
government, the U.S. central bank, or a
U.S. government agency receive a zero
percent risk weight.126 Consistent with
the general risk-based capital rules, the
portion of a deposit or other exposure
insured or otherwise unconditionally
guaranteed by the FDIC or the National
Credit Union Administration also is
assigned a zero percent risk weight. An
exposure conditionally guaranteed by
the U.S. government, its central bank, or
a U.S. government agency receives a 20
percent risk weight.127 This includes an
exposure that is conditionally
guaranteed by the FDIC or the National
Credit Union Administration.
The agencies and the FDIC proposed
in the Standardized Approach NPR to
revise the risk weights for exposures to
foreign sovereigns. The agencies’
general risk-based capital rules
generally assign risk weights to direct
exposures to sovereigns and exposures
directly guaranteed by sovereigns based
on whether the sovereign is a member
of the Organization for Economic Cooperation and Development (OECD)
and, as applicable, whether the
exposure is unconditionally or
conditionally guaranteed by the
sovereign.128
Under the proposed rule, the risk
weight for a foreign sovereign exposure
126 Similar to the general risk-based capital rules,
a claim would not be considered unconditionally
guaranteed by a central government if the validity
of the guarantee is dependent upon some
affirmative action by the holder or a third party, for
example, asset servicing requirements. See 12 CFR
part 3, appendix A, section 1(c)(11) (national banks)
and 12 CFR 167.6 (Federal savings associations)
(OCC); 12 CFR parts 208 and 225, appendix A,
section III.C.1 (Board).
127 Loss-sharing agreements entered into by the
FDIC with acquirers of assets from failed
institutions are considered conditional guarantees
for risk-based capital purposes due to contractual
conditions that acquirers must meet. The
guaranteed portion of assets subject to a losssharing agreement may be assigned a 20 percent
risk weight. Because the structural arrangements for
these agreements vary depending on the specific
terms of each agreement, institutions should
consult with their primary Federal regulator to
determine the appropriate risk-based capital
treatment for specific loss-sharing agreements.
128 12 CFR part 3, appendix A, section 3 (national
banks) and 12 CFR 167.6 (Federal savings
associations) (OCC); 12 CFR parts 208 and 225,
appendix A, section III.C.1 (Board).
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would have been determined using
OECD Country Risk Classifications
(CRCs) (the CRC methodology).129 The
CRCs reflect an assessment of country
risk, used to set interest rate charges for
transactions covered by the OECD
arrangement on export credits. The CRC
methodology classifies countries into
one of eight risk categories (0–7), with
countries assigned to the zero category
having the lowest possible risk
assessment and countries assigned to
the 7 category having the highest
possible risk assessment. Using CRCs to
risk weight sovereign exposures is an
option that is included in the Basel II
standardized framework. The agencies
and the FDIC proposed to map risk
weights ranging from 0 percent to 150
percent to CRCs in a manner consistent
with the Basel II standardized approach,
which provides risk weights for foreign
sovereigns based on country risk scores.
The agencies and the FDIC also
proposed to assign a 150 percent risk
weight to foreign sovereign exposures
immediately upon determining that an
event of sovereign default has occurred
or if an event of sovereign default has
occurred during the previous five years.
The proposal defined sovereign default
as noncompliance by a sovereign with
its external debt service obligations or
the inability or unwillingness of a
sovereign government to service an
existing loan according to its original
terms, as evidenced by failure to pay
principal or interest fully and on a
timely basis, arrearages, or restructuring.
Restructuring would include a
voluntary or involuntary restructuring
that results in a sovereign not servicing
an existing obligation in accordance
with the obligation’s original terms.
The agencies and the FDIC received
several comments on the proposed risk
weights for foreign sovereign exposures.
Some commenters criticized the
proposal, arguing that CRCs are not
sufficiently risk sensitive and basing
risk weights on CRCs unduly benefits
certain jurisdictions with unstable fiscal
positions. A few commenters asserted
that the increased burden associated
with tracking CRCs to determine risk
weights outweighs any increased risk
sensitivity gained by using CRCs
relative to the general risk-based capital
rules. Some commenters also requested
that the CRC methodology be disclosed
so that banking organizations could
perform their own due diligence. One
commenter also indicated that
community banking organizations
129 For more information on the OECD country
risk classification methodology, see OECD,
‘‘Country Risk Classification,’’ available at https://
www.oecd.org/document/49/
0,3746,en_2649_34169_1901105_1_1_1_1,00.html.
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should be permitted to maintain the
treatment under the general risk-based
capital rules.
Following the publication of the
proposed rule, the OECD determined
that certain high-income countries that
received a CRC of 0 in 2012 will no
longer receive any CRC.130
Despite the limitations associated
with risk weighting foreign sovereign
exposures using CRCs, the agencies
have decided to retain this
methodology, modified as described
below to take into account that some
countries will no longer receive a CRC.
Although the agencies recognize that the
risk sensitivity provided by the CRCs is
limited, they consider CRCs to be a
reasonable alternative to credit ratings
for sovereign exposures and the CRC
methodology to be more granular and
risk sensitive than the current riskweighting methodology based solely on
OECD membership. Furthermore, the
OECD regularly updates CRCs and
makes the assessments publicly
available on its Web site.131
Accordingly, the agencies believe that
risk weighting foreign sovereign
exposures with reference to CRCs (as
applicable) should not unduly burden
banking organizations. Additionally, the
150 percent risk weight assigned to
defaulted sovereign exposures should
mitigate the concerns raised by some
commenters that the use of CRCs assigns
inappropriate risk weights to exposures
to countries experiencing fiscal stress.
The final rule assigns risk weights to
foreign sovereign exposures as set forth
in Table 17 below. The agencies
modified the final rule to reflect a
change in OECD practice for assigning
CRCs for certain member countries so
that those member countries that no
longer receive a CRC are assigned a zero
percent risk weight. Applying a zero
percent risk weight to exposures to
these countries is appropriate because
they will remain subject to the same
market credit risk pricing formulas of
the OECD’s rating methodologies that
are applied to all OECD countries with
a CRC of 0. In other words, OECD
130 See https://www.oecd.or/tad/xcred/cat0.htm
Participants to the Arrangement on Officially
Supported Export Credits agreed that the automatic
classification of High Income OECD and High
Income Euro Area countries in Country Risk
Category Zero should be terminated. In the future,
these countries will no longer be classified but will
remain subject to the same market credit risk
pricing disciplines that are applied to all Category
Zero countries. This means that the change will
have no practical impact on the rules that apply to
the provision of official export credits.
131 For more information on the OECD country
risk classification methodology, see OECD,
‘‘Country Risk Classification,’’ available at https://
www.oecd.org/document/49/0,3746,en_2649_
34169_1901105_1_1_1_1,00.html.
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member countries that are no longer
assigned a CRC exhibit a similar degree
of country risk as that of a jurisdiction
with a CRC of zero. The final rule,
therefore, provides a zero percent risk
weight in these cases. Additionally, a
zero percent risk weight for these
countries is generally consistent with
the risk weight they would receive
under the agencies’ general risk-based
capital rules.
TABLE 17—RISK WEIGHTS FOR
SOVEREIGN EXPOSURES
Risk weight
(in percent)
CRC:
0–1 ....................................
2 ........................................
3 ........................................
4–6 ....................................
7 ........................................
0
20
50
100
150
OECD Member with No CRC
0
Non-OECD Member with No
CRC ..................................
100
Sovereign Default .................
150
Consistent with the proposal, the final
rule provides that if a banking
supervisor in a sovereign jurisdiction
allows banking organizations in that
jurisdiction to apply a lower risk weight
to an exposure to the sovereign than
Table 17 provides, a U.S. banking
organization may assign the lower risk
weight to an exposure to the sovereign,
provided the exposure is denominated
in the sovereign’s currency and the U.S.
banking organization has at least an
equivalent amount of liabilities in that
foreign currency.
2. Exposures to Certain Supranational
Entities and Multilateral Development
Banks
Under the general risk-based capital
rules, exposures to certain supranational
entities and MDBs receive a 20 percent
risk weight. Consistent with the Basel II
standardized framework, the agencies
and the FDIC proposed to apply a zero
percent risk weight to exposures to the
Bank for International Settlements, the
European Central Bank, the European
Commission, and the International
Monetary Fund. The agencies and the
FDIC also proposed to apply a zero
percent risk weight to exposures to an
MDB in accordance with the Basel
framework. The proposal defined an
MDB to include the International Bank
for Reconstruction and Development,
the Multilateral Investment Guarantee
Agency, the International Finance
Corporation, the Inter-American
Development Bank, the Asian
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Development Bank, the African
Development Bank, the European Bank
for Reconstruction and Development,
the European Investment Bank, the
European Investment Fund, the Nordic
Investment Bank, the Caribbean
Development Bank, the Islamic
Development Bank, the Council of
Europe Development Bank, and any
other multilateral lending institution or
regional development bank in which the
U.S. government is a shareholder or
contributing member or which the
primary Federal supervisor determines
poses comparable credit risk.
As explained in the proposal, the
agencies believe this treatment is
appropriate in light of the generally
high-credit quality of MDBs, their strong
shareholder support, and a shareholder
structure comprised of a significant
proportion of sovereign entities with
strong creditworthiness. The agencies
have adopted this aspect of the proposal
without change. Exposures to regional
development banks and multilateral
lending institutions that are not covered
under the definition of MDB generally
are treated as corporate exposures
assigned to the 100 percent risk weight
category.
3. Exposures to Government-Sponsored
Enterprises
The general risk-based capital rules
assign a 20 percent risk weight to
exposures to GSEs that are not equity
exposures and a 100 percent risk weight
to GSE preferred stock in the case of the
Board (the OCC has assigned a 20
percent risk weight to GSE preferred
stock).
The agencies and the FDIC proposed
to continue to assign a 20 percent risk
weight to exposures to GSEs that are not
equity exposures and to also assign a
100 percent risk weight to preferred
stock issued by a GSE. As explained in
the proposal, the agencies believe these
risk weights remain appropriate for the
GSEs under their current circumstances,
including those in the conservatorship
of the Federal Housing Finance Agency
and receiving capital support from the
U.S. Treasury. The agencies maintain
that the obligations of the GSEs, as
private corporations whose obligations
are not explicitly guaranteed by the full
faith and credit of the United States,
should not receive the same treatment
as obligations that have such an explicit
guarantee.
4. Exposures to Depository Institutions,
Foreign Banks, and Credit Unions
The general risk-based capital rules
assign a 20 percent risk weight to all
exposures to U.S. depository
institutions and foreign banks
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incorporated in an OECD country.
Under the general risk-based capital
rules, short-term exposures to foreign
banks incorporated in a non-OECD
country receive a 20 percent risk weight
and long-term exposures to such entities
receive a 100 percent risk weight.
The proposed rule would assign a 20
percent risk weight to exposures to U.S.
depository institutions and credit
unions.132 Consistent with the Basel II
standardized framework, under the
proposed rule, an exposure to a foreign
bank would receive a risk weight one
category higher than the risk weight
assigned to a direct exposure to the
foreign bank’s home country, based on
the assignment of risk weights by CRC,
as discussed above.133 A banking
organization would be required to
assign a 150 percent risk weight to an
exposure to a foreign bank immediately
upon determining that an event of
sovereign default has occurred in the
foreign bank’s home country, or if an
event of sovereign default has occurred
in the foreign bank’s home country
during the previous five years.
A few commenters asserted that the
proposed 20 percent risk weight for
exposures to U.S. banking
organizations—when compared to
corporate exposures that are assigned a
100 percent risk weight—would
continue to encourage banking
organizations to become overly
concentrated in the financial sector. The
agencies have concluded that the
proposed 20 percent risk weight is an
appropriate reflection of risk for this
exposure type when taking into
consideration the extensive regulatory
and supervisory frameworks under
which these institutions operate. In
addition, the agencies note that
exposures to the capital of other
financial institutions, including
depository institutions and credit
unions, are subject to deduction from
capital if they exceed certain limits as
set forth in section 22 of the final rule
(discussed above in section V.B of this
preamble). Therefore, the final rule
retains, as proposed, the 20 percent risk
weight for exposures to U.S. banking
organizations.
The agencies have adopted the
proposal with modifications to take into
account the OECD’s decision to
132 A depository institution is defined in section
3 of the Federal Deposit Insurance Act (12 U.S.C.
1813(c)(1)). Under this final rule, a credit union
refers to an insured credit union as defined under
the Federal Credit Union Act (12 U.S.C. 1752(7)).
133 Foreign bank means a foreign bank as defined
in § 211.2 of the Federal Reserve Board’s Regulation
K (12 CFR 211.2), that is not a depository
institution. For purposes of the proposal, home
country meant the country where an entity is
incorporated, chartered, or similarly established.
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withdraw CRCs for certain OECD
member countries. Accordingly,
exposures to a foreign bank in a country
that does not have a CRC, but that is a
member of the OECD, are assigned a 20
percent risk weight and exposures to a
foreign bank in a non-OECD member
country that does not have a CRC
continue to receive a 100 percent risk
weight.
Additionally, the agencies have
adopted the proposed requirement that
exposures to a financial institution that
are included in the regulatory capital of
such financial institution receive a risk
weight of 100 percent, unless the
exposure is (1) An equity exposure, (2)
a significant investment in the capital of
an unconsolidated financial institution
in the form of common stock under
section 22 of the final rule, (3) an
exposure that is deducted from
regulatory capital under section 22 of
the final rule, or (4) an exposure that is
subject to the 150 percent risk weight
under Table 2 of section 32 of the final
rule.
As described in the Standardized
Approach NPR, in 2011, the BCBS
revised certain aspects of the Basel
capital framework to address potential
adverse effects of the framework on
trade finance in low-income
countries.134 In particular, the
framework was revised to remove the
sovereign floor for trade finance-related
claims on banking organizations under
the Basel II standardized approach.135
The proposal incorporated this revision
and would have permitted a banking
organization to assign a 20 percent risk
weight to self-liquidating trade-related
contingent items that arise from the
movement of goods and that have a
maturity of three months or less.136
Consistent with the proposal, the final
rule permits a banking organization to
assign a 20 percent risk weight to selfliquidating, trade-related contingent
items that arise from the movement of
134 See BCBS, ‘‘Treatment of Trade Finance under
the Basel Capital Framework,’’ (October 2011),
available at https://www.bis.org/publ/bcbs205.pdf.
‘‘Low income country’’ is a designation used by the
World Bank to classify economies (see World Bank,
‘‘How We Classify Countries,’’ available at https://
data.worldbank.org/about/country-classifications).
135 The BCBS indicated that it removed the
sovereign floor for such exposures to make access
to trade finance instruments easier and less
expensive for low income countries. Absent
removal of the floor, the risk weight assigned to
these exposures, where the issuing banking
organization is incorporated in a low income
country, typically would be 100 percent.
136 One commenter requested that the agencies
and the FDIC confirm whether short-term selfliquidating trade finance instruments are
considered exempt from the one-year maturity floor
in the advances approaches rule. Section 131(d)(7)
of the final rule provides that a trade-related letter
of credit is exempt from the one-year maturity floor.
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goods and that have a maturity of three
months or less.
As discussed in the proposal,
although the Basel capital framework
permits exposures to securities firms
that meet certain requirements to be
assigned the same risk weight as
exposures to depository institutions, the
agencies do not believe that the risk
profile of securities firms is sufficiently
similar to depository institutions to
justify assigning the same risk weight to
both exposure types. Therefore, the
agencies and the FDIC proposed that
banking organizations assign a 100
percent risk weight to exposures to
securities firms, which is the same risk
weight applied to BHCs, SLHCs, and
other financial institutions that are not
insured depository institutions or credit
unions, as described in section VIII.B of
this preamble.
Several commenters asserted that the
final rule should be consistent with the
Basel framework and permit lower risk
weights for exposures to securities
firms, particularly for securities firms in
a sovereign jurisdiction with a CRC of
0 or 1. The agencies considered these
comments and have concluded that that
exposures to securities firms exhibit a
similar degree of risk as exposures to
other financial institutions that are
assigned a 100 percent risk weight,
because of the nature and risk profile of
their activities, which are more
expansive and exhibit more varied risk
profiles than the activities permissible
for depository institutions and credit
unions. Accordingly, the agencies have
adopted the 100 percent risk weight for
securities firms without change.
5. Exposures to Public-Sector Entities
The proposal defined a PSE as a state,
local authority, or other governmental
subdivision below the level of a
sovereign, which includes U.S. states
and municipalities. The proposed
definition did not include governmentowned commercial companies that
engage in activities involving trade,
commerce, or profit that are generally
conducted or performed in the private
sector. The agencies and the FDIC
proposed to define a general obligation
as a bond or similar obligation that is
backed by the full faith and credit of a
PSE, whereas a revenue obligation
would be defined as a bond or similar
obligation that is an obligation of a PSE,
but which the PSE has committed to
repay with revenues from a specific
project rather than general tax funds. In
the final rule, the agencies are adopting
these definitions as proposed.
The agencies and the FDIC proposed
to assign a 20 percent risk weight to a
general obligation exposure to a PSE
that is organized under the laws of the
United States or any state or political
subdivision thereof, and a 50 percent
risk weight to a revenue obligation
exposure to such a PSE. These are the
risk weights assigned to U.S. states and
municipalities under the general riskbased capital rules.
Some commenters asserted that
available default data does not support
a differentiated treatment between
revenue obligations and general
obligations. In addition, some
commenters contended that higher risk
weights for revenue obligation bonds
would needlessly and adversely affect
state and local agencies’ ability to meet
the needs of underprivileged
constituents. One commenter
specifically recommended assigning a
20 percent risk weight to investmentgrade revenue obligations. Another
commenter recommended that
exposures to U.S. PSEs should receive
the same treatment as exposures to the
U.S. government.
The agencies considered these
comments, including with respect to
burden on state and local programs, but
concluded that the higher regulatory
capital requirement for revenue
obligations is appropriate because those
obligations are dependent on revenue
from specific projects and generally a
PSE is not legally obligated to repay
these obligations from other revenue
sources. Although some evidence may
suggest that there are not substantial
differences in credit quality between
general and revenue obligation
exposures, the agencies believe that
such dependence on project revenue
presents more credit risk relative to a
general repayment obligation of a state
or political subdivision of a sovereign.
Therefore, the proposed differentiation
of risk weights between general
obligation and revenue exposures is
retained in the final rule. The agencies
also continue to believe that PSEs
collectively pose a greater credit risk
than U.S. sovereign debt and, therefore,
are appropriately assigned a higher risk
weight under the final rule.
Consistent with the Basel II
standardized framework, the agencies
and the FDIC proposed to require
banking organizations to risk weight
exposures to a non-U.S. PSE based on
(1) the CRC assigned to the PSE’s home
country and (2) whether the exposure is
a general obligation or a revenue
obligation. The risk weights assigned to
revenue obligations were proposed to be
higher than the risk weights assigned to
a general obligation issued by the same
PSE.
For purposes of the final rule, the
agencies have adopted the proposed risk
weights for non-U.S. PSEs with
modifications to take into account the
OECD’s decision to withdraw CRCs for
certain OECD member countries
(discussed above), as set forth in Table
18 below. Under the final rule,
exposures to a non-U.S. PSE in a
country that does not have a CRC and
is not an OECD member receive a 100
percent risk weight. Exposures to a nonU.S. PSE in a country that has defaulted
on any outstanding sovereign exposure
or that has defaulted on any sovereign
exposure during the previous five years
receive a 150 percent risk weight.
TABLE 18—RISK WEIGHTS FOR EXPOSURES TO NON-U.S. PSE GENERAL OBLIGATIONS AND REVENUE OBLIGATIONS
[In percent]
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Risk weight for
exposures to nonU.S. PSE general obligations
Risk weight for
exposures to nonU.S.PSE revenue obligations
20
50
100
150
20
100
150
50
100
100
150
50
100
150
CRC:
0–1 ............................................................................................
2 ................................................................................................
3 ................................................................................................
4–7 ............................................................................................
OECD Member with No CRC ..........................................................
Non-OECD member with No CRC ..................................................
Sovereign Default ............................................................................
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Consistent with the general risk-based
capital rules as well as the proposed
rule, a banking organization may apply
a different risk weight to an exposure to
a non-U.S. PSE if the banking
organization supervisor in that PSE’s
home country allows supervised
institutions to assign the alternative risk
weight to exposures to that PSE. In no
event, however, may the risk weight for
an exposure to a non-U.S. PSE be lower
than the risk weight assigned to direct
exposures to the sovereign of that PSE’s
home country.
6. Corporate Exposures
Generally consistent with the general
risk-based capital rules, the agencies
and the FDIC proposed to require
banking organizations to assign a 100
percent risk weight to all corporate
exposures, including bonds and loans.
The proposal defined a corporate
exposure as an exposure to a company
that is not an exposure to a sovereign,
the Bank for International Settlements,
the European Central Bank, the
European Commission, the International
Monetary Fund, an MDB, a depository
institution, a foreign bank, a credit
union, a PSE, a GSE, a residential
mortgage exposure, a pre-sold
construction loan, a statutory
multifamily mortgage, a high-volatility
commercial real estate (HVCRE)
exposure, a cleared transaction, a
default fund contribution, a
securitization exposure, an equity
exposure, or an unsettled transaction.
The definition also captured all
exposures that are not otherwise
included in another specific exposure
category.
Several commenters recommended
differentiating the proposed risk weights
for corporate bonds based on a bond’s
credit quality. Other commenters
requested the agencies and the FDIC
align the final rule with the Basel
international standard that aligns risk
weights with credit ratings. A few
commenters asserted that a single 100
percent risk weight would
disproportionately and adversely impact
insurance companies that generally hold
a higher share of corporate bonds in
their investment portfolios. Another
commenter contended that corporate
bonds should receive a 50 percent risk
weight, arguing that other exposures
included in the corporate exposure
category (such as commercial and
industrial bank loans) are empirically of
greater risk than corporate bonds.
One commenter requested that the
standardized approach provide a
distinct capital treatment of a 75 percent
risk weight for retail exposures,
consistent with the international
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standard under Basel II. The agencies
have concluded that the proposed 100
percent risk weight assigned to retail
exposures is appropriate given their risk
profile in the United States and have
retained the proposed treatment in the
final rule. Consistent with the proposal,
the final rule neither defines nor
provides a separate treatment for retail
exposures in the standardized approach.
As described in the proposal, the
agencies removed the use of ratings
from the regulatory capital framework,
consistent with section 939A of the
Dodd-Frank Act. The agencies therefore
evaluated a number of alternatives to
credit ratings to provide a more granular
risk weight treatment for corporate
exposures.137 For example, the agencies
considered market-based alternatives,
such as the use of credit default and
bond spreads, and use of particular
indicators or parameters to differentiate
between relative levels of credit risk.
However, the agencies viewed each of
the possible alternatives as having
significant drawbacks, including their
operational complexity, or insufficient
development. For instance, the agencies
were concerned that bond markets may
sometimes misprice risk and bond
spreads may reflect factors other than
credit risk. The agencies also were
concerned that such approaches could
introduce undue volatility into the riskbased capital requirements.
The agencies considered suggestions
offered by commenters and understand
that a 100 percent risk weight may
overstate the credit risk associated with
some high-quality bonds. However, the
agencies believe that a single risk weight
of less than 100 percent would
understate the risk of many corporate
exposures and, as explained, have not
yet identified an alternative
methodology to credit ratings that
would provide a sufficiently rigorous
basis for differentiating the risk of
various corporate exposures. In
addition, the agencies believe that, on
balance, a 100 percent risk weight is
generally representative of a welldiversified corporate exposure portfolio.
The final rule retains without change
the 100 percent risk weight for all
corporate exposures as well as the
proposed definition of corporate
exposure.
A few commenters requested
clarification on the treatment for
general-account insurance products.
Under the final rule, consistent with the
proposal, if a general-account exposure
is to an organization that is not a
banking organization, such as an
137 See, for example, 76 FR 73526 (Nov. 29, 2011)
and 76 FR 73777 (Nov. 29, 2011).
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insurance company, the exposure must
receive a risk weight of 100 percent.
Exposures to securities firms are subject
to the corporate exposure treatment
under the final rule, as described in
section VIII.B of this preamble.
7. Residential Mortgage Exposures
Under the general risk-based capital
requirements, first-lien residential
mortgages made in accordance with
prudent underwriting standards on
properties that are owner-occupied or
rented typically are assigned to the 50
percent risk-weight category. Otherwise,
residential mortgage exposures are
assigned to the 100 percent risk weight
category.
The proposal would have
substantially modified the risk-weight
framework applicable to residential
mortgage exposures and differed
materially from both the general riskbased capital rules and the Basel capital
framework. The agencies and the FDIC
proposed to divide residential mortgage
exposures into two categories. The
proposal applied relatively low risk
weights to residential mortgage
exposures that did not have product
features associated with higher credit
risk, or ‘‘category 1’’ residential
mortgages as defined in the proposal.
The proposal defined all other
residential mortgage exposures as
‘‘category 2’’ mortgages, which would
receive relatively high risk weights. For
both category 1 and category 2
mortgages, the proposed risk weight
assigned also would have depended on
the mortgage exposure’s LTV ratio.
Under the proposal, a banking
organization would not be able to
recognize private mortgage insurance
(PMI) when calculating the LTV ratio of
a residential mortgage exposure. Due to
the varying degree of financial strength
of mortgage insurance providers, the
agencies stated that they did not believe
that it would be prudent to consider
PMI in the determination of LTV ratios
under the proposal.
The agencies and the FDIC received a
significant number of comments in
opposition to the proposed risk weights
for residential mortgages and in favor of
retaining the risk-weight framework for
residential mortgages in the general riskbased capital rules. Many commenters
asserted that the increased risk weights
for certain mortgages would inhibit
lending to creditworthy borrowers,
particularly when combined with the
other proposed statutory and regulatory
requirements being implemented under
the authority of the Dodd-Frank Act,
and could ultimately jeopardize the
recovery of a still-fragile residential real
estate market. Various commenters
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asserted that the agencies and the FDIC
did not provide sufficient empirical
support for the proposal and stated the
proposal was overly complex and would
not contribute meaningfully to the risk
sensitivity of the regulatory capital
requirements. They also asserted that
the proposal would require some
banking organizations to raise revenue
through other, more risky activities to
compensate for the potential increased
costs.
Commenters also indicated that the
distinction between category 1 and
category 2 residential mortgages would
adversely impact certain loan products
that performed relatively well even
during the recent crisis, such as balloon
loans originated by community banking
organizations. Other commenters
criticized the proposed increased capital
requirements for various loan products,
including balloon and interest-only
mortgages. Community banking
organization commenters in particular
asserted that such mortgage products are
offered to hedge interest-rate risk and
are frequently the only option for a
significant segment of potential
borrowers in their regions.
A number of commenters argued that
the proposal would place U.S. banking
organizations at a competitive
disadvantage relative to foreign banking
organizations subject to the Basel II
standardized framework, which
generally assigns a 35 percent risk
weight to residential mortgage
exposures. Several commenters
indicated that the proposed treatment
would potentially undermine
government programs encouraging
residential mortgage lending to lowerincome individuals and underserved
regions. Commenters also asserted that
PMI should receive explicit recognition
in the final rule through a reduction in
risk weights, given the potential
negative impact on mortgage availability
(particularly to first-time borrowers) of
the proposed risk weights.
In addition to comments on the
specific elements of the proposal, a
significant number of commenters
alleged that the agencies and the FDIC
did not sufficiently consider the
potential impact of other regulatory
actions on the mortgage industry. For
instance, commenters expressed
considerable concern regarding the new
requirements associated with the DoddFrank Act’s qualified mortgage
definition under the Truth in Lending
Act.138 Many of these commenters
138 The proposal was issued prior to publication
of the Consumer Financial Protection Bureau’s final
rule regarding qualified mortgage standards. See 78
FR 6407 (January 30, 2013).
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asserted that when combined with this
proposal, the cumulative effect of the
new regulatory requirements could
adversely impact the residential
mortgage industry.
The agencies and the FDIC also
received specific comments concerning
potential logistical difficulties they
would face implementing the proposal.
Many commenters argued that tracking
loans by LTV and category would be
administratively burdensome, requiring
the development or purchase of new
systems. These commenters requested
that, at a minimum, existing mortgages
continue to be assigned the risk weights
they would receive under the general
risk-based capital rules and exempted
from the proposed rules. Many
commenters also requested clarification
regarding the method for calculating the
LTV for first and subordinate liens, as
well as how and whether a loan could
be reclassified between the two
residential mortgage categories. For
instance, commenters raised various
technical questions on how to calculate
the LTV of a restructured mortgage and
under what conditions a restructured
loan could qualify as a category 1
residential mortgage exposure.
The agencies considered the
comments pertaining to the residential
mortgage proposal, particularly
comments regarding the issuance of new
regulations designed to improve the
quality of mortgage underwriting and to
generally reduce the associated credit
risk, including the final definition of
‘‘qualified mortgage’’ as implemented by
the Consumer Financial Protection
Bureau (CFPB) pursuant to the DoddFrank Act.139 Additionally, the agencies
are mindful of the uncertain
implications that the proposal, along
with other mortgage-related
rulemakings, could have had on the
residential mortgage market,
particularly regarding underwriting and
credit availability. The agencies also
considered the commenters’
observations about the burden of
calculating the risk weights for banking
organizations’ existing mortgage
portfolios, and have taken into account
the commenters’ concerns about the
availability of different mortgage
products across different types of
markets.
In light of these considerations, the
agencies have decided to retain in the
final rule the treatment for residential
mortgage exposures that is currently set
forth in the general risk-based capital
rules. The agencies may develop and
propose changes in the treatment of
residential mortgage exposures in the
139 See
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future, and in that process, the agencies
intend to take into consideration
structural and product market
developments, other relevant
regulations, and potential issues with
implementation across various product
types.
Accordingly, as under the general
risk-based capital rules, the final rule
assigns exposures secured by one-tofour family residential properties to
either the 50 percent or the 100 percent
risk-weight category. Exposures secured
by a first-lien on an owner-occupied or
rented one-to-four family residential
property that meet prudential
underwriting standards, including
standards relating to the loan amount as
a percentage of the appraised value of
the property, are not 90 days or more
past due or carried on non-accrual
status, and that are not restructured or
modified receive a 50 percent risk
weight. If a banking organization holds
the first and junior lien(s) on a
residential property and no other party
holds an intervening lien, the banking
organization must treat the combined
exposure as a single loan secured by a
first lien for purposes of determining the
loan-to-value ratio and assigning a risk
weight. A banking organization must
assign a 100 percent risk weight to all
other residential mortgage exposures.
Under the final rule, a residential
mortgage guaranteed by the federal
government through the Federal
Housing Administration (FHA) or the
Department of Veterans Affairs (VA)
generally will be risk-weighted at 20
percent.
Consistent with the general risk-based
capital rules, under the final rule, a
residential mortgage exposure may be
assigned to the 50 percent risk-weight
category only if it is not restructured or
modified. Under the final rule,
consistent with the proposal, a
residential mortgage exposure modified
or restructured on a permanent or trial
basis solely pursuant to the U.S.
Treasury’s Home Affordable Mortgage
Program (HAMP) is not considered to be
restructured or modified. Several
commenters from community banking
organizations encouraged the agencies
to broaden this exemption and not
penalize banking organizations for
participating in other successful loan
modification programs. As described in
greater detail in the proposal, the
agencies believe that treating mortgage
loans modified pursuant to HAMP in
this manner is appropriate in light of the
special and unique incentive features of
HAMP, and the fact that the program is
offered by the U.S. government to
achieve the public policy objective of
promoting sustainable loan
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modifications for homeowners at risk of
foreclosure in a way that balances the
interests of borrowers, servicers, and
lenders.
8. Pre-Sold Construction Loans and
Statutory Multifamily Mortgages
The general risk-based capital rules
assign either a 50 percent or a 100
percent risk weight to certain one-tofour family residential pre-sold
construction loans and to multifamily
residential loans, consistent with
provisions of the Resolution Trust
Corporation Refinancing, Restructuring,
and Improvement Act of 1991 (RTCRRI
Act).140 The proposal maintained the
same general treatment as the general
risk-based capital rules and clarified
and updated the manner in which the
general risk-based capital rules define
these exposures. Under the proposal, a
pre-sold construction loan would be
subject to a 50 percent risk weight
unless the purchase contract is
cancelled.
The agencies are adopting this aspect
of the proposal without change. The
final rule defines a pre-sold
construction loan, in part, as any oneto-four family residential construction
loan to a builder that meets the
requirements of section 618(a)(1) or (2)
of the RTCRRI Act, and also harmonizes
the agencies’ prior regulations. Under
the final rule, a multifamily mortgage
that does not meet the definition of a
statutory multifamily mortgage is
treated as a corporate exposure.
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9. High-Volatility Commercial Real
Estate
Supervisory experience has
demonstrated that certain acquisition,
development, and construction loans
(which are a subset of commercial real
estate exposures) present particular
risks for which the agencies believe
banking organizations should hold
additional capital. Accordingly, the
agencies and the FDIC proposed to
require banking organizations to assign
a 150 percent risk weight to any HVCRE
exposure, which is higher than the 100
percent risk weight applied to such
loans under the general risk-based
capital rules. The proposal defined an
HVCRE exposure to include any credit
facility that finances or has financed the
140 The RTCRRI Act mandates that each agency
provide in its capital regulations (i) a 50 percent
risk weight for certain one-to-four-family residential
pre-sold construction loans and multifamily
residential loans that meet specific statutory criteria
in the RTCRRI Act and any other underwriting
criteria imposed by the agencies, and (ii) a 100
percent risk weight for one-to-four-family
residential pre-sold construction loans for
residences for which the purchase contract is
cancelled. 12 U.S.C. 1831n, note.
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acquisition, development, or
construction of real property, unless the
facility finances one- to four-family
residential mortgage property, or
commercial real estate projects that
meet certain prudential criteria,
including with respect to the LTV ratio
and capital contributions or expense
contributions of the borrower.
Commenters criticized the proposed
HVCRE definition as overly broad and
suggested an exclusion for certain
acquisition, development, or
construction (ADC) loans, including: (1)
ADC loans that are less than a specific
dollar amount or have a debt service
coverage ratio of 100 percent (rather
than 80 percent, under the agencies’ and
the FDIC’s lending standards); (2)
community development projects or
projects financed by low-income
housing tax credits; and (3) certain loans
secured by agricultural property for the
sole purpose of acquiring land. Several
commenters asserted that the proposed
150 percent risk weight was too high for
secured loans and would hamper local
commercial development. Another
commenter recommended the agencies
and the FDIC increase the number of
HVCRE risk-weight categories to reflect
LTV ratios.
The agencies have considered the
comments and have decided to retain
the 150 percent risk weight for HVCRE
exposures (modified as described
below), given the increased risk of these
activities when compared to other
commercial real estate loans.141 The
agencies believe that segmenting
HVCRE by LTV ratio would introduce
undue complexity without providing a
sufficient improvement in risk
sensitivity. The agencies have also
determined not to exclude from the
HVCRE definition ADC loans that are
characterized by a specified dollar
amount or loans with a debt service
coverage ratio greater than 80 percent
because an arbitrary threshold would
likely not capture certain ADC loans
with elevated risks. Consistent with the
proposal, a commercial real estate loan
that is not an HVCRE exposure is treated
as a corporate exposure.
Many commenters requested
clarification as to whether all
commercial real estate or ADC loans are
considered HVCRE exposures.
Consistent with the proposal, the final
rule’s HVCRE definition only applies to
a specific subset of ADC loans and is,
therefore, not applicable to all
commercial real estate loans.
Specifically, some commenters sought
141 See the definition of ‘‘high-volatility
commercial real estate exposure’’ in section 2 of the
final rule.
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clarification on whether a facility would
remain an HVCRE exposure for the life
of the loan and whether owner-occupied
commercial real estate loans are
included in the HVCRE definition. The
agencies note that when the life of the
ADC project concludes and the credit
facility is converted to permanent
financing in accordance with the
banking organization’s normal lending
terms, the permanent financing is not an
HVCRE exposure. Thus, a loan
permanently financing owner-occupied
commercial real estate is not an HVCRE
exposure. Given these clarifications, the
agencies believe that many concerns
regarding the potential adverse impact
on commercial development were, in
part, driven by a lack of clarity
regarding the definition of the HVCRE,
and believe that the treatment of HVCRE
exposures in the final rule appropriately
reflects their risk relative to other
commercial real estate exposures.
Commenters also sought clarification
as to whether cash or securities used to
purchase land counts as borrowercontributed capital. In addition, a few
commenters requested further
clarification on what constitutes
contributed capital for purposes of the
final rule. Consistent with existing
guidance, cash used to purchase land is
a form of borrower contributed capital
under the HVCRE definition.
In response to the comments, the final
rule amends the proposed HVCRE
definition to exclude loans that finance
the acquisition, development, or
construction of real property that would
qualify as community development
investments. The final rule does not
require a banking organization to have
an investment in the real property for it
to qualify for the exemption: Rather, if
the real property is such that an
investment in that property would
qualify as a community development
investment, then a facility financing
acquisition, development, or
construction of that property would
meet the terms of the exemption. The
agencies have, however, determined not
to give an automatic exemption from the
HVCRE definition to all ADC loans to
businesses or farms that have gross
annual revenues of $1 million or less,
although they could qualify for another
exemption from the definition. For
example, an ADC loan to a small
business with annual revenues of under
$1 million that meets the LTV ratio and
contribution requirements set forth in
paragraph (3) of the definition would
qualify for that exemption from the
definition as would a loan that finances
real property that: Provides affordable
housing (including multi-family rental
housing) for low to moderate income
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individuals; is used in the provision of
community services for low to moderate
income individuals; or revitalizes or
stabilizes low to moderate income
geographies, designated disaster areas,
or underserved areas specifically
determined by the federal banking
agencies based on the needs of low- and
moderate-income individuals in those
areas. The final definition also exempts
ADC loans for the purchase or
development of agricultural land, which
is defined as all land known to be used
or usable for agricultural purposes (such
as crop and livestock production),
provided that the valuation of the
agricultural land is based on its value
for agricultural purposes and the
valuation does not consider any
potential use of the land for nonagricultural commercial development or
residential development.
10. Past-Due Exposures
Under the general risk-based capital
rules, the risk weight of a loan does not
change if the loan becomes past due,
with the exception of certain residential
mortgage loans. The Basel II
standardized approach provides risk
weights ranging from 50 to 150 percent
for exposures, except sovereign
exposures and residential mortgage
exposures, that are more than 90 days
past due to reflect the increased risk of
loss. Accordingly, to reflect the
impaired credit quality of such
exposures, the agencies and the FDIC
proposed to require a banking
organization to assign a 150 percent risk
weight to an exposure that is not
guaranteed or not secured (and that is
not a sovereign exposure or a residential
mortgage exposure) if it is 90 days or
more past due or on nonaccrual.
A number of commenters maintained
that the proposed 150 percent risk
weight is too high for various reasons.
Specifically, several commenters
asserted that ALLL is already reflected
in the risk-based capital numerator, and
therefore an increased risk weight
double-counts the risk of a past-due
exposure. Other commenters
characterized the increased risk weight
as procyclical and burdensome
(particularly for community banking
organizations), and maintained that it
would unnecessarily discourage lending
and loan modifications or workouts.
The agencies have considered the
comments and have decided to retain
the proposed 150 percent risk weight for
past-due exposures in the final rule. The
agencies note that the ALLL is intended
to cover estimated, incurred losses as of
the balance sheet date, rather than
unexpected losses. The higher risk
weight on past due exposures ensures
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sufficient regulatory capital for the
increased probability of unexpected
losses on these exposures. The agencies
believe that any increased capital
burden, potential rise in procyclicality,
or impact on lending associated with
the 150 percent risk weight is justified
given the overall objective of better
capturing the risk associated with the
impaired credit quality of these
exposures.
One commenter requested
clarification as to whether a banking
organization could reduce the risk
weight for past-due exposures from 150
percent when the carrying value is
charged down to the amount expected
to be recovered. For the purposes of the
final rule, a banking organization must
apply a 150 percent risk weight to all
past-due exposures, including any
amount remaining on the balance sheet
following a charge-off, to reflect the
increased uncertainty as to the recovery
of the remaining carrying value.
11. Other Assets
Generally consistent with the general
risk-based capital rules, the agencies
have decided to adopt, as proposed, the
risk weights described below for
exposures not otherwise assigned to a
specific risk weight category.
Specifically, a banking organization
must assign:
(1) A zero percent risk weight to cash
owned and held in all of a banking
organization’s offices or in transit; gold
bullion held in the banking
organization’s own vaults, or held in
another depository institution’s vaults
on an allocated basis to the extent gold
bullion assets are offset by gold bullion
liabilities; and to exposures that arise
from the settlement of cash transactions
(such as equities, fixed income, spot
foreign exchange and spot commodities)
with a CCP where there is no
assumption of ongoing counterparty
credit risk by the CCP after settlement
of the trade and associated default fund
contributions;
(2) A 20 percent risk weight to cash
items in the process of collection; and
(3) A 100 percent risk weight to all
assets not specifically assigned a
different risk weight under the final rule
(other than exposures that would be
deducted from tier 1 or tier 2 capital),
including deferred acquisition costs
(DAC) and value of business acquired
(VOBA).
In addition, subject to the proposed
transition arrangements under section
300 of the final rule, a banking
organization must assign:
(1) A 100 percent risk weight to DTAs
arising from temporary differences that
the banking organization could realize
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through net operating loss carrybacks;
and
(2) A 250 percent risk weight to the
portion of MSAs and DTAs arising from
temporary differences that the banking
organization could not realize through
net operating loss carrybacks that are
not deducted from common equity tier
1 capital pursuant to section 22(d).
The agencies and the FDIC received a
few comments on the treatment of DAC
and VOBA. DAC represents certain costs
incurred in the acquisition of a new
contract or renewal insurance contract
that are capitalized pursuant to GAAP.
VOBA refers to assets that reflect
revenue streams from insurance policies
purchased by an insurance company.
One commenter asked for clarification
on risk weights for other types of
exposures that are not assigned a
specific risk weight under the proposal.
Consistent with the proposal, under the
final rule these assets receive a 100
percent risk weight, together with other
assets not specifically assigned a
different risk weight under the NPR.
Consistent with the general risk-based
capital rules, the final rule retains the
limited flexibility to address situations
where exposures of a banking
organization that are not exposures
typically held by depository institutions
do not fit wholly within the terms of
another risk-weight category. Under the
final rule, a banking organization may
assign such exposures to the risk-weight
category applicable under the capital
rules for BHCs or covered SLHCs,
provided that (1) the banking
organization is not authorized to hold
the asset under applicable law other
than debt previously contracted or
similar authority; and (2) the risks
associated with the asset are
substantially similar to the risks of
assets that are otherwise assigned to a
risk-weight category of less than 100
percent under subpart D of the final
rule.
C. Off-Balance Sheet Items
1. Credit Conversion Factors
Under the proposed rule, as under the
general risk-based capital rules, a
banking organization would calculate
the exposure amount of an off-balance
sheet item by multiplying the offbalance sheet component, which is
usually the contractual amount, by the
applicable credit conversion factors
(CCF). This treatment would apply to all
off-balance sheet items, such as
commitments, contingent items,
guarantees, certain repo-style
transactions, financial standby letters of
credit, and forward agreements. The
proposed rule, however, introduced
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new CCFs applicable to certain
exposures, such as a higher CCF for
commitments with an original maturity
of one year or less that are not
unconditionally cancelable.
Commenters offered a number of
suggestions for revising the proposed
CCFs that would be applied to offbalance sheet exposures. Commenters
generally asked for lower CCFs that,
according to the commenters, are more
directly aligned with a particular offbalance sheet exposure’s loss history. In
addition, some commenters asked the
agencies and the FDIC to conduct a
calibration study to show that the
proposed CCFs were appropriate.
The agencies have decided to retain
the proposed CCFs for off-balance sheet
exposures without change for purposes
of the final rule. The agencies believe
that the proposed CCFs meet the
agencies’ goals of improving risk
sensitivity and implementing higher
capital requirements for certain
exposures through a simple
methodology. Furthermore, alternatives
proposed by commenters, such as
exposure measures tied directly to a
particular exposure’s loss history,
would create significant operational
burdens for many small- and mid-sized
banking organizations, by requiring
them to keep accurate historical records
of losses and continuously adjust their
capital requirements for certain
exposures to account for new loss data.
Such a system would be difficult for the
agencies to monitor, as the agencies
would need to verify the accuracy of
historical loss data and ensure that
capital requirements are properly
applied across institutions.
Incorporation of additional factors, such
as loss history or increasing the number
of CCF categories, would detract from
the agencies’ stated goal of simplicity in
its capital treatment of off-balance sheet
exposures. Additionally, the agencies
believe that the CCFs, as proposed, were
properly calibrated to reflect the risk
profiles of the exposures to which they
are applied and do not believe a
calibration study is required.
Accordingly, under the final rule, as
proposed, a banking organization may
apply a zero percent CCF to the unused
portion of commitments that are
unconditionally cancelable by the
banking organization. For purposes of
the final rule, a commitment means any
legally binding arrangement that
obligates a banking organization to
extend credit or to purchase assets.
Unconditionally cancelable means a
commitment for which a banking
organization may, at any time, with or
without cause, refuse to extend credit
(to the extent permitted under
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applicable law). In the case of a
residential mortgage exposure that is a
line of credit, a banking organization
can unconditionally cancel the
commitment if it, at its option, may
prohibit additional extensions of credit,
reduce the credit line, and terminate the
commitment to the full extent permitted
by applicable law. If a banking
organization provides a commitment
that is structured as a syndication, the
banking organization is only required to
calculate the exposure amount for its
pro rata share of the commitment.
The proposed rule provided a 20
percent CCF for commitments with an
original maturity of one year or less that
are not unconditionally cancelable by a
banking organization, and for selfliquidating, trade-related contingent
items that arise from the movement of
goods with an original maturity of one
year or less.
Some commenters argued that the
proposed designation of a 20 percent
CCF for certain exposures was too high.
For example, they requested that the
final rule continue the current practice
of applying a zero percent CCF to all
unfunded lines of credit with less than
one year maturity, regardless of the
lender’s ability to unconditionally
cancel the line of credit. They also
requested a CCF lower than 20 percent
for the unused portions of letters of
credit extended to a small, mid-market,
or trade finance company with
durations of less than one year or less.
These commenters asserted that current
market practice for these lines have
covenants based on financial ratios, and
any increase in riskiness that violates
the contractual minimum ratios would
prevent the borrower from drawing
down the unused portion.
For purposes of the final rule, the
agencies are retaining the 20 percent
CCF, as it accounts for the elevated level
of risk banking organizations face when
extending short-term commitments that
are not unconditionally cancelable.
Although the agencies understand
certain contractual provisions are
common in the market, these practices
are not static, and it is more appropriate
from a regulatory standpoint to base a
CCF on whether a commitment is
unconditionally cancellable. A banking
organization must apply a 20 percent
CCF to a commitment with an original
maturity of one year or less that is not
unconditionally cancellable by the
banking organization. The final rule also
maintains the 20 percent CCF for selfliquidating, trade-related contingent
items that arise from the movement of
goods with an original maturity of one
year or less. The final rule also requires
a banking organization to apply a 50
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percent CCF to commitments with an
original maturity of more than one year
that are not unconditionally cancelable
by the banking organization, and to
transaction-related contingent items,
including performance bonds, bid
bonds, warranties, and performance
standby letters of credit.
Some commenters requested
clarification regarding the treatment of
commitments to extend letters of credit.
They argued that these commitments are
no more risky than commitments to
extend loans and should receive similar
treatment (20 percent or 50 percent
CCF). For purposes of the final rule, the
agencies note that section 33(a)(2)
allows banking organizations to apply
the lower of the two applicable CCFs to
the exposures related to commitments to
extend letters of credit. Banking
organizations will need to make this
determination based upon the
individual characteristics of each letter
of credit.
Under the final rule, a banking
organization must apply a 100 percent
CCF to off-balance sheet guarantees,
repurchase agreements, creditenhancing representations and
warranties that are not securitization
exposures, securities lending or
borrowing transactions, financial
standby letters of credit, and forward
agreements, and other similar
exposures. The off-balance sheet
component of a repurchase agreement
equals the sum of the current fair values
of all positions the banking organization
has sold subject to repurchase. The offbalance sheet component of a securities
lending transaction is the sum of the
current fair values of all positions the
banking organization has lent under the
transaction. For securities borrowing
transactions, the off-balance sheet
component is the sum of the current fair
values of all non-cash positions the
banking organization has posted as
collateral under the transaction. In
certain circumstances, a banking
organization may instead determine the
exposure amount of the transaction as
described in section 37 of the final rule.
In contrast to the general risk-based
capital rules, which require capital for
securities lending and borrowing
transactions and repurchase agreements
that generate an on-balance sheet
exposure, the final rule requires a
banking organization to hold risk-based
capital against all repo-style
transactions, regardless of whether they
generate on-balance sheet exposures, as
described in section 37 of the final rule.
One commenter disagreed with this
treatment and requested an exemption
from the capital treatment for offbalance sheet repo-style exposures.
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However, the agencies adopted this
approach because banking organizations
face counterparty credit risk when
engaging in repo-style transactions, even
if those transactions do not generate onbalance sheet exposures, and thus
should not be exempt from risk-based
capital requirements.
2. Credit-Enhancing Representations
and Warranties
Under the general risk-based capital
rules, a banking organization is subject
to a risk-based capital requirement
when it provides credit-enhancing
representations and warranties on assets
sold or otherwise transferred to third
parties as such positions are considered
recourse arrangements.142 However, the
general risk-based capital rules do not
impose a risk-based capital requirement
on assets sold or transferred with
representations and warranties that (1)
Contain early default clauses or similar
warranties that permit the return of, or
premium refund clauses covering, oneto-four family first-lien residential
mortgage loans for a period not to
exceed 120 days from the date of
transfer; and (2) contain premium
refund clauses that cover assets
guaranteed, in whole or in part, by the
U.S. government, a U.S. government
agency, or a U.S. GSE, provided the
premium refund clauses are for a period
not to exceed 120 days; or (3) permit the
return of assets in instances of fraud,
misrepresentation, or incomplete
documentation.143
In contrast, under the proposal, if a
banking organization provides a creditenhancing representation or warranty
on assets it sold or otherwise transferred
to third parties, including early default
clauses that permit the return of, or
premium refund clauses covering, oneto-four family residential first mortgage
loans, the banking organization would
treat such an arrangement as an offbalance sheet guarantee and apply a 100
percent CCF to determine the exposure
amount, provided the exposure does not
meet the definition of a securitization
exposure. The agencies and the FDIC
proposed a different treatment than the
one under the general risk-based capital
rules because of the risk to which
banking organizations are exposed
while credit-enhancing representations
and warranties are in effect. Some
commenters asked for clarification on
what qualifies as a credit-enhancing
142 12 CFR part 3, appendix A, section 4(a)(11)
and 12 CFR 167.6(b) (OCC); 12 CFR parts 208 and
225 appendix A, section III.B.3.a.xii (Board).
143 12 CFR part 3, appendix A, section 4(a)(8) and
12 CFR 167.6(b) (OCC); 12 CFR part 208, appendix
A, section II.B.3.a.ii.1 and 12 CFR part 225,
appendix A, section III.B.3.a.ii.(1) (Board).
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representation and warranty, and
commenters made numerous
suggestions for revising the proposed
definition. In particular, they disagreed
with the agencies’ and the FDIC’s
proposal to remove the exemptions
related to early default clauses and
premium refund clauses since these
representations and warranties generally
are considered to be low risk exposures
and banking organizations are not
currently required to hold capital
against these representations and
warranties.
Some commenters encouraged the
agencies and the FDIC to retain the 120day safe harbor from the general riskbased capital rules, which would not
require holding capital against assets
sold with certain early default clauses of
120 days or less. These commenters
argued that the proposal to remove the
120-day safe harbor would impede the
ability of banking organizations to make
loans and would increase the cost of
credit to borrowers. Furthermore,
certain commenters asserted that
removal of the 120-day safe harbor was
not necessary for loan portfolios that are
well underwritten, those for which putbacks are rare, and where the banking
organization maintains robust buyback
reserves.
After reviewing the comments, the
agencies decided to retain in the final
rule the 120-day safe harbor in the
definition of credit-enhancing
representations and warranties for early
default and premium refund clauses on
one-to-four family residential mortgages
that qualify for the 50 percent risk
weight as well as for premium refund
clauses that cover assets guaranteed, in
whole or in part, by the U.S.
government, a U.S. government agency,
or a U.S. GSE. The agencies determined
that retaining the safe harbor would
help to address commenters’ confusion
about what qualifies as a creditenhancing representation and warranty.
Therefore, consistent with the general
risk-based capital rules, under the final
rule, credit-enhancing representations
and warranties will not include (1) Early
default clauses and similar warranties
that permit the return of, or premium
refund clauses covering, one-to-four
family first-lien residential mortgage
loans that qualify for a 50 percent risk
weight for a period not to exceed 120
days from the date of transfer; 144 (2)
premium refund clauses that cover
assets guaranteed by the U.S.
government, a U.S. Government agency,
or a GSE, provided the premium refund
144 These warranties may cover only those loans
that were originated within 1 year of the date of
transfer.
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clauses are for a period not to exceed
120 days from the date of transfer; or (3)
warranties that permit the return of
underlying exposures in instances of
misrepresentation, fraud, or incomplete
documentation.
Some commenters requested
clarification from the agencies and the
FDIC regarding representations made
about the value of the underlying
collateral of a sold loan. For example,
many purchasers of mortgage loans
originated by banking organizations
require that the banking organization
repurchase the loan if the value of the
collateral is other than as stated in the
documentation provided to the
purchaser or if there were any material
misrepresentations in the appraisal
process. The agencies confirm that such
representations meets the
‘‘misrepresentation, fraud, or
incomplete documentation’’ exclusion
in the definition of credit-enhancing
representations and warranties and is
not subject to capital treatment.
A few commenters also requested
clarification regarding how the
definition of credit-enhancing
representations and warranties in the
proposal interacts with Federal Home
Loan Mortgage Corporation (FHLMC),
Federal National Mortgage Association
(FNMA), and Government National
Mortgage Association (GNMA) sales
conventions. These same commenters
also requested verification in the final
rule that mortgages sold with
representations and warranties would
all receive a 100 percent risk weight,
regardless of the characteristics of the
mortgage exposure. First, the definition
of credit-enhancing representations and
warranties described in this final rule is
separate from the sales conventions
required by FLHMA, FNMA, and
GNMA. Those entities will continue to
set their own requirements for
secondary sales, including
representation and warranty
requirements. Second, the risk weights
applied to mortgage exposures
themselves are not affected by the
inclusion of representations and
warranties. Mortgage exposures will
continue to receive either a 50 or 100
percent risk weight, as outlined in
section 32(g) of this final rule, regardless
of the inclusion of representations and
warranties when they are sold in the
secondary market. If such
representations and warranties meet the
rule’s definition of credit-enhancing
representations and warranties, then the
institution must maintain regulatory
capital against the associated credit risk.
Some commenters disagreed with the
proposed methodology for determining
the capital requirement for
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representations and warranties, and
offered alternatives that they argued
would conform to existing market
practices and better incentivize highquality underwriting. Some commenters
indicated that many originators already
hold robust buyback reserves and
argued that the agencies and the FDIC
should require originators to hold
adequate liquidity in their buyback
reserves, instead of requiring a
duplicative capital requirement. Other
commenters asked that any capital
requirement be directly aligned to that
originator’s history of honoring
representation and warranty claims.
These commenters stated that
originators who underwrite high-quality
loans should not be required to hold as
much capital against their
representations and warranties as
originators who exhibit what the
commenters referred to as ‘‘poor
underwriting standards.’’ Finally, a few
commenters requested that the agencies
and the FDIC completely remove, or
significantly reduce, capital
requirements for representations and
warranties. They argue that the market
is able to regulate itself, as a banking
organization will not be able to sell its
loans in the secondary market if they are
frequently put back by the buyers.
The agencies considered these
alternatives and have decided to finalize
the proposed methodology for
determining the capital requirement
applied to representations and
warranties without change. The
agencies are concerned that buyback
reserves could be inadequate, especially
if the housing market enters another
prolonged downturn. Robust and clear
capital requirements, in addition to
separate buyback reserves held by
originators, better ensure that
representation and warranty claims will
be fulfilled in times of stress.
Furthermore, capital requirements based
upon originators’ historical
representation and warranty claims are
not only operationally difficult to
implement and monitor, but they can
also be misleading. Underwriting
standards at firms are not static and can
change over time. The agencies believe
that capital requirements based on past
performance of a particular underwriter
do not always adequately capture the
current risks faced by that firm. The
agencies believe that the incorporation
of the 120-day safe harbor in the final
rule as discussed above addresses many
of the commenters’ concerns.
Some commenters requested
clarification on the duration of the
capital treatment for credit-enhancing
representations and warranties. For
instance, some commenters questioned
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whether capital is required for creditenhancing representations and
warranties after the contractual life of
the representations and warranties has
expired or whether capital has to be
held for the life of the asset. Banking
organizations are not required to hold
capital for any credit-enhancing
representation and warranty after the
expiration of the representation or
warranty, regardless of the maturity of
the underlying loan.
Additionally, commenters indicated
that market practice for some
representations and warranties for sold
mortgages stipulates that originators
only need to refund the buyer any
servicing premiums and other earned
fees in cases of early default, rather than
requiring putback of the underlying loan
to the seller. These commenters sought
clarification as to whether the proposal
would have required them to hold
capital against the value of the
underlying loan or only for the premium
or fees that could be subject to a refund,
as agreed upon in their contract with the
buyer. For purposes of the final rule, a
banking organization must hold capital
only for the maximum contractual
amount of the banking organization’s
exposure under the representations and
warranties. In the case described by the
commenters, the banking organization
would hold capital against the value of
the servicing premium and other earned
fees, rather than the value of the
underlying loan, for the duration
specified in the representations and
warranties agreement.
Some commenters also requested
exemptions from the proposed
treatment of representations and
warranties for particular originators,
types of transactions, or asset categories.
In particular, many commenters asked
for an exemption for community
banking organizations, claiming that the
proposed treatment would lessen credit
availability and increase the costs of
lending. One commenter argued that
bona fide mortgage sale agreements
should be exempt from capital
requirements. Other commenters
requested an exemption for the portion
of any off-balance sheet asset that is
subject to a risk retention requirement
under section 941 of the Dodd-Frank
Act and any regulations promulgated
thereunder.145 Some commenters also
requested that the agencies and the
FDIC delay action on the proposal until
the risk retention rule is finalized. Other
commenters also requested exemptions
for qualified mortgages (QM) and
‘‘prime’’ mortgage loans.
145 See
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62093
The agencies have decided not to
adopt any of the specific exemptions
suggested by the commenters. Although
community banking organizations are
critical to ensure the flow of credit to
small businesses and individual
borrowers, providing them with an
exemption from the proposed treatment
of credit-enhancing representations and
warranties would be inconsistent with
safety and soundness because the risks
from these exposures to community
banking organizations are no different
than those to other banking
organizations. The agencies also have
not provided exemptions in this
rulemaking to portions of off-balance
sheet assets subject to risk retention,
QM, and ‘‘prime loans.’’ The relevant
agencies have not yet adopted a final
rule implementing the risk retention
provisions of section 941 of the DoddFrank Act, and the agencies, therefore,
do not believe it is appropriate to
provide an exemption relating to risk
retention in this final rule. In addition,
while the QM rulemaking is now
final,146 the agencies believe it is
appropriate to first evaluate how the
QM designation affects the mortgage
market before requiring less capital to be
held against off-balance sheet assets that
cover these loans. As noted above, the
incorporation in the final rule of the
120-day safe harbor addresses many of
the concerns about burden.
The risk-based capital treatment for
off-balance sheet items in this final rule
is consistent with section 165(k) of the
Dodd-Frank Act which provides that, in
the case of a BHC with $50 billion or
more in total consolidated assets, the
computation of capital, for purposes of
meeting capital requirements, shall take
into account any off-balance-sheet
activities of the company.147 The final
rule complies with the requirements of
section 165(k) of the Dodd-Frank Act by
requiring a BHC to hold risk-based
capital for its off-balance sheet
exposures, as described in sections 31,
33, 34 and 35 of the final rule.
146 See
12 CFR part 1026.
165(k) of the Dodd-Frank Act (12
U.S.C. 5365(k)). This section defines an off-balance
sheet activity as an existing liability of a company
that is not currently a balance sheet liability, but
may become one upon the happening of some
future event. Such transactions may include direct
credit substitutes in which a banking organization
substitutes its own credit for a third party;
irrevocable letters of credit; risk participations in
bankers’ acceptances; sale and repurchase
agreements; asset sales with recourse against the
seller; interest rate swaps; credit swaps;
commodities contracts; forward contracts; securities
contracts; and such other activities or transactions
as the Board may define through a rulemaking.
147 Section
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D. Over-the-Counter Derivative
Contracts
In the Standardized Approach NPR,
the agencies and the FDIC proposed
generally to retain the treatment of OTC
derivatives provided under the general
risk-based capital rules, which is similar
to the current exposure method (CEM)
for determining the exposure amount for
OTC derivative contracts contained in
the Basel II standardized framework.148
Proposed revisions to the treatment of
the OTC derivative contracts included
an updated definition of an OTC
derivative contract, a revised conversion
factor matrix for calculating the PFE, a
revision of the criteria for recognizing
the netting benefits of qualifying master
netting agreements and of financial
collateral, and the removal of the 50
percent risk weight cap for OTC
derivative contracts.
The agencies and the FDIC received a
number of comments on the proposed
CEM relating to OTC derivatives. These
comments generally focused on the
revised conversion factor matrix, the
proposed removal of the 50 percent cap
on risk weights for OTC derivative
transactions in the general risk-based
capital rules, and commenters’ view that
there is a lack of risk sensitivity in the
calculation of the exposure amount of
OTC derivatives and netting benefits. A
specific discussion of the comments on
particular aspects of the proposal
follows.
One commenter asserted that the
proposed conversion factors for
common interest rate and foreign
exchange contracts, and risk
participation agreements (a simplified
form of credit default swaps) (set forth
in Table 19 below), combined with the
removal of the 50 percent risk weight
cap, would drive up banking
organizations’ capital requirements
associated with these routine
transactions and result in much higher
transaction costs for small businesses.
Another commenter asserted that the
zero percent conversion factor assigned
to interest rate derivatives with a
remaining maturity of one year or less
is not appropriate as the PFE incorrectly
assumes all interest rate derivatives
always can be covered by taking a
position in a liquid market.
148 The general risk-based capital rules for savings
associations regarding the calculation of credit
equivalent amounts for derivative contracts differ
from the rules for other banking organizations. (See
12 CFR 167(a)(2) (Federal savings associations) and
12 CFR 390.466(a)(2) (state savings associations)).
The savings association rules address only interest
rate and foreign exchange rate contracts and include
certain other differences. Accordingly, the
description of the general risk-based capital rules in
this preamble primarily reflects the rules applicable
to state and national banks and BHCs.
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The agencies acknowledge that the
standardized matrix of conversion
factors may be too simplified for some
banking organizations. The agencies
believe, however, that the matrix
approach appropriately balances the
policy goals of simplicity and risksensitivity, and that the conversion
factors themselves have been
appropriately calibrated for the products
to which they relate.
Some commenters supported
retention of the 50 percent risk weight
cap for derivative exposures under the
general risk-based capital rules.
Specifically, one commenter argued that
the methodology for calculating the
exposure amount without the 50 percent
risk weight cap would result in
inappropriately high capital charge
unless the methodology were amended
to recognize the use of netting and
collateral. Accordingly, the commenter
encouraged the agencies and the FDIC to
retain the 50 percent risk weight cap
until the BCBS enhances the CEM to
improve risk-sensitivity.
The agencies believe that as the
market for derivatives has developed,
the types of counterparties acceptable to
participants have expanded to include
counterparties that merit a risk weight
greater than 50 percent. In addition, the
agencies are aware of the ongoing work
of the BCBS to improve the current
exposure method and expect to consider
any necessary changes to update the
exposure amount calculation when the
BCBS work is completed.
Some commenters suggested that the
agencies and the FDIC allow the use of
internal models approved by the
primary Federal supervisor as an
alternative to the proposal, consistent
with Basel III. The agencies chose not to
incorporate all of the methodologies
included in the Basel II standardized
framework in the final rule. The
agencies believe that, given the range of
banking organizations that are subject to
the final rule in the United States, it is
more appropriate to permit only the
proposed non-models based
methodology for calculating OTC
derivatives exposure amounts under the
standardized approach. For larger and
more complex banking organizations,
the use of the internal model
methodology and other models-based
methodologies is permitted under the
advanced approaches rule. One
commenter asked the agencies and the
FDIC to provide a definition for
‘‘netting,’’ as the meaning of this term
differs widely under various master
netting agreements used in industry
practice. Another commenter asserted
that net exposures are likely to
understate actual exposures and the risk
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of early close-out posed to banking
organizations facing financial
difficulties, that the conversion factors
for PFE are inappropriate, and that a
better measure of risk tied to gross
exposure is needed. With respect to the
definition of netting, the agencies note
that the definition of ‘‘qualifying master
netting agreement’’ provides a
functional definition of netting. With
respect to the use of net exposure for
purposes of determining PFE, the
agencies believe that, in light of the
existing international framework to
enforce netting arrangements together
with the conditions for recognizing
netting that are included in this final
rule, the use of net exposure is
appropriate in the context of a riskbased counterparty credit risk charge
that is specifically intended to address
default risk. The final rule also
continues to limit full recognition of
netting for purposes of calculating PFE
for counterparty credit risk under the
standardized approach.149
Other commenters suggested adopting
broader recognition of netting under the
PFE calculation for netting sets, using a
factor of 85 percent rather than 60
percent in the formula for recognizing
netting effects to be consistent with the
BCBS CCP interim framework (which is
defined and discussed in section VIII.E
of this preamble, below). Another
commenter suggested implementing a
15 percent haircut on the calculated
exposure amount for failure to recognize
risk mitigants and portfolio
diversification. With respect to the
commenters’ request for greater
recognition of netting in the calculation
of PFE, the agencies note that the BCBS
CCP interim framework’s use of 85
percent recognition of netting was
limited to the calculation of the
hypothetical capital requirement of the
QCCP for purposes of determining a
clearing member banking organization’s
risk-weighted asset amount for its
default fund contribution. As such, the
final rule retains the proposed formula
for recognizing netting effects for OTC
derivative contracts that was set out in
the proposal. The agencies expect to
consider whether it would be necessary
to propose any changes to the CEM once
BCBS discussions on this topic are
complete.
The proposed rule placed a cap on the
PFE of sold credit protection, equal to
the net present value of the amount of
unpaid premiums. One commenter
questioned the appropriateness of the
proposed cap, and suggested that a
seller’s exposure be measured as the
gross exposure amount of the credit
149 See
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protection provided on the name
referenced in the credit derivative
contract. The agencies believe that the
proposed approach is appropriate for
measuring counterparty credit risk
because it reflects the amount a banking
organization may lose on its exposure to
the counterparty that purchased
protection. The exposure amount on a
sold credit derivative would be
calculated separately under section
34(a).
Another commenter asserted that
current credit exposure (netted and
unnetted) understates or ignores the risk
that the mark is inaccurate. Generally,
the agencies expect a banking
organization to have in place policies
and procedures regarding the valuation
of positions, and that those processes
would be reviewed in connection with
routine and periodic supervisory
examinations of a banking organization.
The final rule generally adopts the
proposed treatment for OTC derivatives
without change. Under the final rule, as
under the general risk-based capital
rules, a banking organization is required
to hold risk-based capital for
counterparty credit risk for an OTC
derivative contract. As defined in the
rule, a derivative contract is a financial
contract whose value is derived from
the values of one or more underlying
assets, reference rates, or indices of asset
values or reference rates. A derivative
contract includes an interest rate,
exchange rate, equity, or a commodity
derivative contract, a credit derivative,
and any other instrument that poses
similar counterparty credit risks.
Derivative contracts also include
unsettled securities, commodities, and
foreign exchange transactions with a
contractual settlement or delivery lag
that is longer than the lesser of the
market standard for the particular
instrument or five business days. This
applies, for example, to mortgagebacked securities (MBS) transactions
that the GSEs conduct in the To-BeAnnounced market.
Under the final rule, an OTC
derivative contract does not include a
derivative contract that is a cleared
transaction, which is subject to a
specific treatment as described in
section VIII.E of this preamble.
However, an OTC derivative contract
includes an exposure of a banking
organization that is a clearing member
banking organization to its clearing
member client where the clearing
member banking organization is either
acting as a financial intermediary and
enters into an offsetting transaction with
a CCP or where the clearing member
banking organization provides a
guarantee to the CCP on the
performance of the client. The rationale
for this treatment is the banking
organization’s continued exposure
directly to the risk of the clearing
member client. In recognition of the
62095
shorter close-out period for these
transactions, however, the final rule
permits a banking organization to apply
a scaling factor to recognize the shorter
holding period as discussed in section
VIII.E of this preamble.
To determine the risk-weighted asset
amount for an OTC derivative contract
under the final rule, a banking
organization must first determine its
exposure amount for the contract and
then apply to that amount a risk weight
based on the counterparty, eligible
guarantor, or recognized collateral.
For a single OTC derivative contract
that is not subject to a qualifying master
netting agreement (as defined further
below in this section), the rule requires
the exposure amount to be the sum of
(1) the banking organization’s current
credit exposure, which is the greater of
the fair value or zero, and (2) PFE,
which is calculated by multiplying the
notional principal amount of the OTC
derivative contract by the appropriate
conversion factor, in accordance with
Table 19 below.
Under the final rule, the conversion
factor matrix includes the additional
categories of OTC derivative contracts as
illustrated in Table 19. For an OTC
derivative contract that does not fall
within one of the specified categories in
Table 19, the final rule requires PFE to
be calculated using the ‘‘other’’
conversion factor.
TABLE 19—CONVERSION FACTOR MATRIX FOR OTC DERIVATIVE CONTRACTS 150
Remaining
maturity 151
Interest rate
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One year or less ..........
Greater than one year
and less than or
equal to five years ....
Greater than five years
Foreign
exchange rate
and gold
13:14 Oct 10, 2013
Credit (noninvestmentgrade
reference
asset)
Precious
metals
(except gold)
Equity
Other
0.00
0.01
0.05
0.10
0.06
0.07
0.10
0.005
0.015
0.05
0.075
0.05
0.05
0.10
0.10
0.08
0.10
0.07
0.08
0.12
0.15
For multiple OTC derivative contracts
subject to a qualifying master netting
agreement, a banking organization must
calculate the exposure amount by
adding the net current credit exposure
and the adjusted sum of the PFE
amounts for all OTC derivative contracts
subject to the qualifying master netting
agreement. Under the final rule, the net
current credit exposure is the greater of
zero and the net sum of all positive and
negative fair values of the individual
OTC derivative contracts subject to the
qualifying master netting agreement.
The adjusted sum of the PFE amounts
must be calculated as described in
section 34(a)(2)(ii) of the final rule.
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(investmentgrade
reference
asset) 152
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Under the final rule, to recognize the
netting benefit of multiple OTC
150 For a derivative contract with multiple
exchanges of principal, the conversion factor is
multiplied by the number of remaining payments in
the derivative contract.
151 For a derivative contract that is structured
such that on specified dates any outstanding
exposure is settled and the terms are reset so that
the market value of the contract is zero, the
remaining maturity equals the time until the next
reset date. For an interest rate derivative contract
with a remaining maturity of greater than one year
that meets these criteria, the minimum conversion
factor is 0.005.
152 A banking organization must use the column
labeled ‘‘Credit (investment-grade reference asset)’’
for a credit derivative whose reference asset is an
outstanding unsecured long-term debt security
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derivative contracts, the contracts must
be subject to a qualifying master netting
agreement; however, unlike under the
general risk-based capital rules, under
the final rule for most transactions, a
banking organization may rely on
sufficient legal review instead of an
opinion on the enforceability of the
netting agreement as described
below.153 The final rule defines a
without credit enhancement that is investment
grade. A banking organization must use the column
labeled ‘‘Credit (non-investment-grade reference
asset)’’ for all other credit derivatives.
153 Under the general risk-based capital rules, to
recognize netting benefits a banking organization
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qualifying master netting agreement as
any written, legally enforceable netting
agreement that creates a single legal
obligation for all individual transactions
covered by the agreement upon an event
of default (including receivership,
insolvency, liquidation, or similar
proceeding) provided that certain
conditions set forth in section 3 of the
final rule are met.154 These conditions
include requirements with respect to the
banking organization’s right to terminate
the contract and liquidate collateral and
meeting certain standards with respect
to legal review of the agreement to
ensure its meets the criteria in the
definition.
The legal review must be sufficient so
that the banking organization may
conclude with a well-founded basis
that, among other things, the contract
would be found legal, binding, and
enforceable under the law of the
relevant jurisdiction and that the
contract meets the other requirements of
the definition. In some cases, the legal
review requirement could be met by
reasoned reliance on a commissioned
legal opinion or an in-house counsel
analysis. In other cases, for example,
those involving certain new derivative
transactions or derivative counterparties
in jurisdictions where a banking
organization has little experience, the
banking organization would be expected
to obtain an explicit, written legal
opinion from external or internal legal
counsel addressing the particular
situation.
Under the final rule, if an OTC
derivative contract is collateralized by
financial collateral, a banking
organization must first determine the
exposure amount of the OTC derivative
contract as described in this section of
the preamble. Next, to recognize the
credit risk mitigation benefits of the
financial collateral, a banking
organization could use the simple
approach for collateralized transactions
as described in section 37(b) of the final
rule. Alternatively, if the financial
collateral is marked-to-market on a daily
basis and subject to a daily margin
maintenance requirement, a banking
must enter into a bilateral master netting agreement
with its counterparty and obtain a written and wellreasoned legal opinion of the enforceability of the
netting agreement for each of its netting agreements
that cover OTC derivative contracts.
154 The final rule adds a new section 3:
Operational requirements for counterparty credit
risk. This section organizes substantive
requirements related to cleared transactions,
eligible margin loans, qualifying cross-product
master netting agreements, qualifying master
netting agreements, and repo-style transactions in a
central place to assist banking organizations in
determining their legal responsibilities. These
substantive requirements are consistent with those
included in the proposal.
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organization could adjust the exposure
amount of the contract using the
collateral haircut approach described in
section 37(c) of the final rule.
Similarly, if a banking organization
purchases a credit derivative that is
recognized under section 36 of the final
rule as a credit risk mitigant for an
exposure that is not a covered position
under subpart F, it is not required to
compute a separate counterparty credit
risk capital requirement for the credit
derivative, provided it does so
consistently for all such credit
derivative contracts. Further, where
these credit derivative contracts are
subject to a qualifying master netting
agreement, the banking organization
must either include them all or exclude
them all from any measure used to
determine the counterparty credit risk
exposure to all relevant counterparties
for risk-based capital purposes.
Under the final rule, a banking
organization must treat an equity
derivative contract as an equity
exposure and compute its risk-weighted
asset amount according to the simple
risk-weight approach (SRWA) described
in section 52 (unless the contract is a
covered position under the market risk
rule). If the banking organization risk
weights a contract under the SRWA
described in section 52, it may choose
not to hold risk-based capital against the
counterparty risk of the equity contract,
so long as it does so for all such
contracts. Where the OTC equity
contracts are subject to a qualified
master netting agreement, a banking
organization either includes or excludes
all of the contracts from any measure
used to determine counterparty credit
risk exposures. If the banking
organization is treating an OTC equity
derivative contract as a covered position
under subpart F, it also must calculate
a risk-based capital requirement for
counterparty credit risk of the contract
under this section.
In addition, if a banking organization
provides protection through a credit
derivative that is not a covered position
under subpart F of the final rule, it must
treat the credit derivative as an exposure
to the underlying reference asset and
compute a risk-weighted asset amount
for the credit derivative under section
32 of the final rule. The banking
organization is not required to compute
a counterparty credit risk capital
requirement for the credit derivative, as
long as it does so consistently for all
such OTC credit derivative contracts.
Further, where these credit derivative
contracts are subject to a qualifying
master netting agreement, the banking
organization must either include all or
exclude all such credit derivatives from
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any measure used to determine
counterparty credit risk exposure to all
relevant counterparties for risk-based
capital purposes.
Where the banking organization
provides protection through a credit
derivative treated as a covered position
under subpart F, it must compute a
supplemental counterparty credit risk
capital requirement using an amount
determined under section 34 for OTC
credit derivative contracts or section 35
for credit derivatives that are cleared
transactions. In either case, the PFE of
the protection provider would be
capped at the net present value of the
amount of unpaid premiums.
Under the final rule, the risk weight
for OTC derivative transactions is not
subject to any specific ceiling,
consistent with the Basel capital
framework.
Although the agencies generally
adopted the proposal without change,
the final rule has been revised to add a
provision regarding the treatment of a
clearing member banking organization’s
exposure to a clearing member client (as
described below under ‘‘Cleared
Transactions,’’ a transaction between a
clearing member banking organization
and a client is treated as an OTC
derivative exposure). However, the final
rule recognizes the shorter close-out
period for cleared transactions that are
derivative contracts, such that a clearing
member banking organization can
reduce its exposure amount to its client
by multiplying the exposure amount by
a scaling factor of no less than 0.71. See
section VIII.E of this preamble, below,
for additional discussion.
E. Cleared Transactions
The BCBS and the agencies support
incentives designed to encourage
clearing of derivative and repo-style
transactions 155 through a CCP wherever
possible in order to promote
transparency, multilateral netting, and
robust risk-management practices.
Although there are some risks
associated with CCPs, as discussed
below, the agencies believe that CCPs
generally help improve the safety and
soundness of the derivatives and repostyle transactions markets through the
multilateral netting of exposures,
establishment and enforcement of
collateral requirements, and the
promotion of market transparency.
As discussed in the proposal, when
developing Basel III, the BCBS
recognized that as more transactions
move to central clearing, the potential
for risk concentration and systemic risk
155 See section 2 of the final rule for the definition
of a repo-style transaction.
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increases. To address these concerns, in
the period preceding the proposal, the
BCBS sought comment on a more risksensitive approach for determining
capital requirements for banking
organizations’ exposures to CCPs.156 In
addition, to encourage CCPs to maintain
strong risk-management procedures, the
BCBS sought comment on a proposal for
lower risk-based capital requirements
for derivative and repo-style transaction
exposures to CCPs that meet the
standards established by the Committee
on Payment and Settlement Systems
(CPSS) and International Organization
of Securities Commissions (IOSCO).157
Exposures to such entities, termed
QCCPs in the final rule, would be
subject to lower risk weights than
exposures to CCPs that did not meet
those criteria.
Consistent with the BCBS proposals
and the CPSS–IOSCO standards, the
agencies and the FDIC sought comment
on specific risk-based capital
requirements for cleared derivative and
repo-style transactions that are designed
to incentivize the use of CCPs, help
reduce counterparty credit risk, and
promote strong risk management of
CCPs to mitigate their potential for
systemic risk. In contrast to the general
risk-based capital rules, which permit a
banking organization to exclude certain
derivative contracts traded on an
exchange from the risk-based capital
calculation, the proposal would have
required a banking organization to hold
risk-based capital for an outstanding
derivative contract or a repo-style
transaction that has been cleared
through a CCP, including an exchange.
The proposal also included a capital
requirement for default fund
contributions to CCPs. In the case of
non-qualifying CCPs (that is, CCPs that
do not meet the risk-management,
supervision, and other standards for
QCCPs outlined in the proposal), the
risk-weighted asset amount for default
fund contributions to such CCPs would
be equal to the sum of the banking
organization’s default fund
contributions to the CCPs multiplied by
1,250 percent. In the case of QCCPs, the
risk-weighted asset amount would be
calculated according to a formula based
on the hypothetical capital requirement
for a QCCP, consistent with the Basel
capital framework. The proposal
included a formula with inputs
including the exposure amount of
156 See ‘‘Capitalisation of Banking Organization
Exposures to Central Counterparties’’ (November
2011) (CCP consultative release), available at https://
www.bis.org/publ/bcbs206.pdf.
157 See CPSS–IOSCO, ‘‘Recommendations for
Central Counterparties’’ (November 2004), available
at https://www.bis.org/publ/cpss64.pdf?noframes=1.
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transactions cleared through the QCCP,
collateral amounts, the number of
members of the QCCP, and default fund
contributions.
Following issuance of the proposal,
the BCBS issued an interim framework
for the capital treatment of bank
exposures to CCPs (BCBS CCP interim
framework).158 The BCBS CCP interim
framework reflects several key changes
from the CCP consultative release,
including: (1) A provision to allow a
clearing member banking organization
to apply a scalar when using the CEM
(as described below) in the calculation
of its exposure amount to a client (or
use a reduced margin period of risk
when using the internal models
methodology (IMM) to calculate
exposure at default (EAD) under the
advanced approaches rule); (2) revisions
to the risk weights applicable to a
clearing member banking organization’s
exposures when such clearing member
banking organization guarantees QCCP
performance; (3) a provision to permit
clearing member banking organizations
to choose from one of two formulaic
methodologies for determining the
capital requirement for default fund
contributions; and (4) revisions to the
CEM formula to recognize netting to a
greater extent for purposes of
calculating the capital requirement for
default fund contributions.
The agencies and the FDIC received a
number of comments on the proposal
relating to cleared transactions.
Commenters also encouraged the
agencies and the FDIC to revise certain
aspects of the proposal in a manner
consistent with the BCBS CCP interim
framework.
Some commenters asserted that the
definition of QCCP should be revised,
specifically by including a definitive list
of QCCPs rather than requiring each
banking organization to demonstrate
that a CCP meets certain qualifying
criteria. The agencies believe that a
static list of QCCPs would not reflect the
potentially dynamic nature of a CCP,
and that banking organizations are
situated to make this determination on
an ongoing basis.
Some commenters recommended
explicitly including derivatives clearing
organizations (DCOs) and securitiesbased swap clearing agencies in the
definition of a QCCP. Commenters also
suggested including in the definition of
QCCP any CCP that the CFTC or SEC
exempts from registration because it is
deemed by the CFTC or SEC to be
subject to ‘‘comparable, comprehensive
158 See ‘‘Capital requirements for bank exposures
to central counterparties’’ (July 2012), available at
https://www.bis.org/publ/bcbs227.pdf.
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62097
supervision’’ by another regulator. The
agencies note that such registration (or
exemption from registration based on
being subject to ‘‘comparable,
comprehensive supervision’’) does not
necessarily mean that the CCP is subject
to, or in compliance with, the standards
established by the CPSS and IOSCO. In
contrast, a designated FMU, which is
included in the definition of QCCP, is
subject to regulation that corresponds to
such standards.
Another commenter asserted that,
consistent with the BCBS CCP interim
framework, the final rule should
provide for the designation of a QCCP
by the agencies in the absence of a
national regime for authorization and
licensing of CCPs. The final rule has not
been amended to include this aspect of
the BCBS CCP interim framework
because the agencies believe a national
regime for authorizing and licensing
CCPs is a critical mechanism to ensure
the compliance and ongoing monitoring
of a CCP’s adherence to internationally
recognized risk-management standards.
Another commenter requested that a
three-month grace period apply for
CCPs that cease to be QCCPs. The
agencies note that such a grace period
was included in the proposed rule, and
the final rule retains the proposed
definition without substantive
change.159
With respect to the proposed
definition of cleared transaction, some
commenters asserted that the definition
should recognize omnibus accounts
because their collateral is bankruptcyremote. The agencies agree with these
commenters and have revised the
operational requirements for cleared
transactions to include an explicit
reference to such accounts.
The BCBS CCP interim framework
requires trade portability to be ‘‘highly
likely,’’ as a condition of whether a
trade satisfies the definition of cleared
transaction. One commenter who
encouraged the agencies and the FDIC to
adopt the standards set forth in the
BCBS CCP interim framework sought
clarification of the meaning of ‘‘highly
likely’’ in this context. The agencies
clarify that, consistent with the BCBS
CCP interim framework, if there is clear
precedent for transactions to be
transferred to a non-defaulting clearing
member upon the default of another
clearing member (commonly referred to
as ‘‘portability’’) and there are no
indications that such practice will not
continue, then these factors should be
considered, when assessing whether
client positions are portable. The
159 This provision is located in sections 35 and
133 of the final rule.
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definition of ‘‘cleared transaction’’ in
the final rule is discussed in further
detail below.
Another commenter sought
clarification on whether reasonable
reliance on a commissioned legal
opinion for foreign financial
jurisdictions could satisfy the
‘‘sufficient legal review’’ requirement
for bankruptcy remoteness of client
positions. The agencies believe that
reasonable reliance on a commissioned
legal opinion could satisfy this
requirement. Another commenter
expressed concern that the proposed
framework for cleared transactions
would capture securities
clearinghouses, and encouraged the
agencies to clarify their intent with
respect to such entities for purposes of
the final rule. The agencies note that the
definition of ‘‘cleared transaction’’ refers
only to OTC derivatives and repo-style
transactions. As a result, securities
clearinghouses are not within the scope
of the cleared transactions framework.
One commenter asserted that the
agencies and the FDIC should recognize
varying close-out period conventions for
specific cleared products, specifically
exchange-traded derivatives. This
commenter also asserted that the
agencies and the FDIC should adjust the
holding period assumptions or allow
CCPs to use alternative methods to
compute the appropriate haircut for
cleared transactions. For purposes of
this final rule, the agencies retained a
standard close-out period in the interest
of avoiding unnecessary complexity,
and note that cleared transactions with
QCCPs attract extremely low risk
weights (generally, 2 or 4 percent),
which, in part, is in recognition of the
shorter close-out period involved in
cleared transactions.
Another commenter requested
confirmation that the risk weight
applicable to the trade exposure amount
for a cleared credit default swap (CDS)
could be substituted for the risk weight
assigned to an exposure that was hedged
by the cleared CDS, that is, the
substitution treatment described in
sections 36 and 134 would apply. The
agencies confirm that under the final
rule, a banking organization may apply
the substitution treatment of sections 36
or 134 to recognize the credit risk
mitigation benefits of a cleared CDS as
long as the CDS is an eligible credit
derivative and meets the other criteria
for recognition. Thus, if a banking
organization purchases an eligible credit
derivative as a hedge of an exposure and
the eligible credit derivative qualifies as
a cleared transaction, the banking
organization may substitute the risk
weight applicable to the cleared
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transaction under sections 35 or 133 of
the final rule (instead of using the risk
weight associated with the protection
provider).160 Furthermore, the agencies
have modified the definition of eligible
guarantor to include a QCCP.
Another commenter asserted that the
final rule should decouple the risk
weights applied to collateral exposure
and those assigned to other components
of trade exposure to recognize the
separate components of risk. The
agencies note that, if collateral is
bankruptcy remote, then it would not be
included in the trade exposure amount
calculation (see sections 35(b)(2) and
133(b)(2) of the final rule). The agencies
also note that such collateral must be
risk weighted in accordance with other
sections of the final rule as appropriate,
to the extent that the posted collateral
remains an asset on a banking
organization’s balance sheet.
A number of commenters addressed
the use of the CEM for purposes of
calculating a capital requirement for a
default fund contribution to a CCP
(Kccp).161 Some commenters asserted
that the CEM is not appropriate for
determining the hypothetical capital
requirement for a QCCP (Kccp) under the
proposed formula because it lacks risk
sensitivity and sophistication, and was
not developed for centrally-cleared
transactions. Another commenter
asserted that the use of CEM should be
clarified in the clearing context,
specifically, whether the modified CEM
approach would permit the netting of
offsetting positions booked under
different ‘‘desk IDs’’ or ‘‘hub accounts’’
for a given clearing member banking
organization. Another commenter
encouraged the agencies and the FDIC to
allow banking organizations to use the
IMM to calculate Kccp. Another
commenter encouraged the agencies and
the FDIC to continue to work with the
BCBS to harmonize international and
domestic capital rules for cleared
transactions.
Although the agencies recognize that
the CEM has certain limitations, the
agencies consider the CEM, as modified
for cleared transactions, to be a
reasonable approach that would
produce consistent results across
banking organizations. Regarding the
commenter’s request for clarification of
netting positions across ‘‘desk IDs’’ or
‘‘hub accounts,’’ the CEM would
recognize netting across such
160 See ‘‘Basel III counterparty credit risk and
exposures to central counterparties—Frequently
asked questions’’ (December 2012 (update of FAQs
published in November 2012)), available at https://
www.bis.org/publ/bcbs237.pdf.
161 See section VIII.D of this preamble for a
description of the CEM.
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transactions if such netting is legally
enforceable upon a CCP’s default.
Moreover, the agencies believe that the
use of models either by the CCP, whose
model would not be subject to review
and approval by the agencies, or by the
banking organizations, whose models
may vary significantly, likely would
produce inconsistent results that would
not serve as a basis for comparison
across banking organizations. The
agencies recognize that additional work
is being performed by the BCBS to
revise the CCP capital framework and
the CEM. The agencies expect to modify
the final rule to incorporate the BCBS
improvements to the CCP capital
framework and CEM through the normal
rulemaking process.
Other commenters suggested that the
agencies and the FDIC not allow
preferential treatment for
clearinghouses, which they asserted are
systemically critical institutions. In
addition, some of these commenters
argued that the agency clearing model
should receive a more favorable capital
requirement because the agency
relationship facilitates protection and
portability of client positions in the
event of a clearing member default,
compared to the back-to-back principal
model. As noted above, the agencies
acknowledge that as more transactions
move to central clearing, the potential
for risk concentration and systemic risk
increases. As noted in the proposal, the
risk weights applicable to cleared
transactions with QCCPs (generally 2 or
4 percent) represent an increase for
many cleared transactions as compared
to the general risk-based capital rules
(which exclude from the risk-based ratio
calculations exchange rate contracts
with an original maturity of fourteen or
fewer calendar days and derivative
contracts traded on exchanges that
require daily receipt and payment of
cash variation margin),162 in part to
reflect the increased concentration and
systemic risk inherent in such
transactions. In regards to the agency
clearing model, the agencies note that a
clearing member banking organization
that acts as an agent for a client and that
guarantees the client’s performance to
the QCCP would have no exposure to
the QCCP to risk weight. The exposure
arising from the guarantee would be
treated as an OTC derivative with a
reduced holding period, as discussed
below.
162 See 12 CFR part 3, appendix A, section
3(b)(7)(iv) (national banks) and 12 CFR
167.6(a)(2)(iv)(E) (Federal savings associations)
(OCC); 12 CFR part 208, appendix A paragraph
III.E.1.e; 12 CFR part 225, appendix A paragraph
III.E.1.e (Board).
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Another commenter suggested that
the final rule address the treatment of
unfunded default fund contribution
amounts and potential future
contributions to QCCPs, noting that the
treatment of these potential exposures is
not addressed in the BCBS CCP interim
framework. The agencies have clarified
in the final rule that if a banking
organization’s unfunded default fund
contribution to a CCP is unlimited, the
banking organization’s primary Federal
supervisor will determine the riskweighted asset amount for such default
fund contribution based on factors such
as the size, structure, and membership
of the CCP and the riskiness of its
transactions. The final rule does not
contemplate unlimited default fund
contributions to QCCPs because defined
default fund contribution amounts are a
prerequisite to being a QCCP.
Another commenter asserted that it is
unworkable to require securities lending
transactions to be conducted through a
CCP, and that it would be easier and
more sensible to make the appropriate
adjustments in the final rule to ensure
a capital treatment for securities lending
transactions that is proportional to their
actual risks. The agencies note that the
proposed rule would not have required
securities lending transactions to be
cleared. The agencies also acknowledge
that clearing may not be widely
available for securities lending
transactions, and believe that the
collateral haircut approach (sections
37(c) and 132(b) of the final rule) and
for advanced approaches banking
organizations, the simple value-at-risk
(VaR) and internal models
methodologies (sections 132(b)(3) and
(d) of the final rule) are an appropriately
risk-sensitive exposure measure for noncleared securities lending exposures.
One commenter asserted that end
users and client-cleared trades would be
disadvantaged by the proposal.
Although there may be increased
transaction costs associated with the
introduction of the CCP framework, the
agencies believe that the overall risk
mitigation that should result from the
capital requirements generated by the
framework will help promote financial
stability, and that the measures the
agencies have taken in the final rule to
incentivize client clearing are aimed at
addressing the commenters’ concerns.
Several commenters suggested that the
proposed rule created a disincentive for
client clearing because of the clearing
member banking organization’s
exposure to the client. The agencies
agree with the need to mitigate
disincentives for client clearing in the
methodology, and have amended the
final rule to reflect a lower margin
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period of risk, or holding period, as
applicable, as discussed further below.
Commenters suggested delaying
implementation of a cleared
transactions framework in the final rule
until the BCBS CCP interim framework
is finalized, implementing the BCBS
CCP interim framework in the final rule
pending finalization of the BCBS
interim framework, or providing a
transition period for banking
organizations to be able to comply with
some of the requirements. A number of
commenters urged the agencies and the
FDIC to incorporate all substantive
changes of the BCBS CCP interim
framework, ranging from minor
adjustments to more material
modifications.
After considering the comments and
reviewing the standards in the BCBS
CCP interim framework, the agencies
believe that the modifications to capital
standards for cleared transactions in the
BCBS CCP interim framework are
appropriate and believe that they would
result in modifications that address
many commenters’ concerns.
Furthermore, the agencies believe that it
is prudent to implement the BCBS CCP
interim framework, rather than wait for
the final framework, because the
changes in the BCBS CCP interim
framework represent a sound approach
to mitigating the risks associated with
cleared transactions. Accordingly, the
agencies have incorporated the material
elements of the BCBS CCP interim
framework into the final rule. In
addition, given the delayed effective
date of the final rule, the agencies
believe that an additional transition
period, as suggested by some
commenters, is not necessary.
The material changes to the proposed
rule to incorporate the CCP interim rule
are described below. Other than these
changes, the final rule retains the capital
requirements for cleared transaction
exposures generally as proposed by the
agencies and the FDIC. As noted in the
proposal, the international discussions
are ongoing on these issues, and the
agencies will revisit this issue once the
Basel capital framework is revised.
1. Definition of Cleared Transaction
The final rule defines a cleared
transaction as an exposure associated
with an outstanding derivative contract
or repo-style transaction that a banking
organization or clearing member has
entered into with a CCP (that is, a
transaction that a CCP has accepted).163
163 For example, the agencies expect that a
transaction with a derivatives clearing organization
(DCO) would meet the criteria for a cleared
transaction. A DCO is a clearinghouse, clearing
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Cleared transactions include the
following: (1) A transaction between a
CCP and a clearing member banking
organization for the banking
organization’s own account; (2) a
transaction between a CCP and a
clearing member banking organization
acting as a financial intermediary on
behalf of its clearing member client; (3)
a transaction between a client banking
organization and a clearing member
where the clearing member acts on
behalf of the client banking organization
and enters into an offsetting transaction
with a CCP; and (4) a transaction
between a clearing member client and a
CCP where a clearing member banking
organization guarantees the performance
of the clearing member client to the
CCP. Such transactions must also satisfy
additional criteria provided in section 3
of the final rule, including bankruptcy
remoteness of collateral, transferability
criteria, and portability of the clearing
member client’s position. As explained
above, the agencies have modified the
definition in the final rule to specify
that regulated omnibus accounts to meet
the requirement for bankruptcy
remoteness.
A banking organization is required to
calculate risk-weighted assets for all of
its cleared transactions, whether the
banking organization acts as a clearing
member (defined as a member of, or
direct participant in, a CCP that is
entitled to enter into transactions with
the CCP) or a clearing member client
(defined as a party to a cleared
transaction associated with a CCP in
which a clearing member acts either as
a financial intermediary with respect to
the party or guarantees the performance
of the party to the CCP).
Derivative transactions that are not
cleared transactions because they do not
meet all the criteria, are OTC derivative
transactions. For example, if a
transaction submitted to the CCP is not
accepted by the CCP because the terms
of the transaction submitted by the
clearing members do not match or
because other operational issues are
identified by the CCP, the transaction
does not meet the definition of a cleared
transaction and is an OTC derivative
transaction. If the counterparties to the
transaction resolve the issues and
association, clearing corporation, or similar entity
that enables each party to an agreement, contract,
or transaction to substitute, through novation or
otherwise, the credit of the DCO for the credit of
the parties; arranges or provides, on a multilateral
basis, for the settlement or netting of obligations; or
otherwise provides clearing services or
arrangements that mutualize or transfer credit risk
among participants. To qualify as a DCO, an entity
must be registered with the U.S. Commodity
Futures Trading Commission and comply with all
relevant laws and procedures.
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resubmit the transaction and it is
accepted, the transaction would then be
a cleared transaction. A cleared
transaction does not include an
exposure of a banking organization that
is a clearing member to its clearing
member client where the banking
organization is either acting as a
financial intermediary and enters into
an offsetting transaction with a CCP or
where the banking organization
provides a guarantee to the CCP on the
performance of the client. Under the
standardized approach, as discussed
below, such a transaction is an OTC
derivative transaction with the exposure
amount calculated according to section
34(e) of the final rule or a repo-style
transaction with the exposure amount
calculated according to section 37(c) of
the final rule. Under the advanced
approaches rule, such a transaction is
treated as either an OTC derivative
transaction with the exposure amount
calculated according to sections
132(c)(8) or (d)(5)(iii)(C) of the final rule
or a repo-style transaction with the
exposure amount calculated according
to sections 132(b) or (d) of the final rule.
2. Exposure Amount Scalar for
Calculating for Client Exposures
Under the proposal, a transaction
between a clearing member banking
organization and a client was treated as
an OTC derivative exposure, with the
exposure amount calculated according
to sections 34 or 132 of the proposal.
The agencies acknowledged in the
proposal that this treatment could have
created disincentives for banking
organizations to facilitate client
clearing. Commenters’ feedback and the
BCBS CCP interim framework’s
treatment on this subject provided
alternatives to address the incentive
concern.
Consistent with comments and the
BCBS CCP interim framework, under
the final rule, a clearing member
banking organization must treat its
counterparty credit risk exposure to
clients as an OTC derivative contract,
irrespective of whether the clearing
member banking organization
guarantees the transaction or acts as an
intermediary between the client and the
QCCP. Consistent with the BCBS CCP
interim framework, to recognize the
shorter close-out period for cleared
transactions, under the standardized
approach a clearing member banking
organization may calculate its exposure
amount to a client by multiplying the
exposure amount, calculated using the
CEM, by a scaling factor of no less than
0.71, which represents a five-day
holding period. A clearing member
banking organization must use a longer
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holding period and apply a larger
scaling factor to its exposure amount in
accordance with Table 20 if it
determines that a holding period longer
than five days is appropriate. A banking
organization’s primary Federal
supervisor may require a clearing
member banking organization to set a
longer holding period if the primary
Federal supervisor determines that a
longer period is commensurate with the
risks associated with the transaction.
The agencies believe that the
recognition of a shorter close-out period
appropriately captures the risk
associated with such transactions while
furthering the policy goal of promoting
central clearing.
TABLE 20—HOLDING PERIODS AND
SCALING FACTORS
Holding period (days)
Scaling factor
5
6
7
8
9
10
0.71
0.77
0.84
0.89
0.95
1.00
3. Risk Weighting for Cleared
Transactions
Under the final rule, to determine the
risk-weighted asset amount for a cleared
transaction, a clearing member client
banking organization or a clearing
member banking organization must
multiply the trade exposure amount for
the cleared transaction by the
appropriate risk weight, determined as
described below. The trade exposure
amount is calculated as follows:
(1) For a cleared transaction that is a
derivative contract or a netting set of
derivatives contracts, the trade exposure
amount is equal to the exposure amount
for the derivative contract or netting set
of derivative contracts, calculated using
the CEM for OTC derivative contracts
(described in sections 34 or 132(c) of the
final rule) or for advanced approaches
banking organizations that use the IMM,
under section 132(d) of the final rule),
plus the fair value of the collateral
posted by the clearing member client
banking organization and held by the
CCP or clearing member in a manner
that is not bankruptcy remote; and
(2) For a cleared transaction that is a
repo-style transaction or a netting set of
repo-style transactions, the trade
exposure amount is equal to the
exposure amount calculated under the
collateral haircut approach used for
financial collateral (described in section
37(c) and 132(b) of the final rule) (or for
advanced approaches banking
organizations the IMM under section
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132(d) of the final rule) plus the fair
value of the collateral posted by the
clearing member client banking
organization that is held by the CCP or
clearing member in a manner that is not
bankruptcy remote.
The trade exposure amount does not
include any collateral posted by a
clearing member client banking
organization or clearing member
banking organization that is held by a
custodian in a manner that is
bankruptcy remote 164 from the CCP,
clearing member, other counterparties of
the clearing member, and the custodian
itself. In addition to the capital
requirement for the cleared transaction,
the banking organization remains
subject to a capital requirement for any
collateral provided to a CCP, a clearing
member, or a custodian in connection
with a cleared transaction in accordance
with section 32 or 131 of the final rule.
Consistent with the BCBS CCP interim
framework, the risk weight for a cleared
transaction depends on whether the
CCP is a QCCP. Central counterparties
that are designated FMUs and foreign
entities regulated and supervised in a
manner equivalent to designated FMUs
are QCCPs. In addition, a CCP could be
a QCCP under the final rule if it is in
sound financial condition and meets
certain standards that are consistent
with BCBS expectations for QCCPs, as
set forth in the QCCP definition.
A clearing member banking
organization must apply a 2 percent risk
weight to its trade exposure amount to
a QCCP. A banking organization that is
a clearing member client may apply a 2
percent risk weight to the trade
exposure amount only if:
(1) The collateral posted by the
clearing member client banking
organization to the QCCP or clearing
member is subject to an arrangement
that prevents any losses to the clearing
member client due to the joint default
or a concurrent insolvency, liquidation,
or receivership proceeding of the
clearing member and any other clearing
member clients of the clearing member,
and
(2) The clearing member client
banking organization has conducted
sufficient legal review to conclude with
a well-founded basis (and maintains
sufficient written documentation of that
legal review) that in the event of a legal
challenge (including one resulting from
default or a liquidation, insolvency, or
receivership proceeding) the relevant
court and administrative authorities
164 Under the final rule, bankruptcy remote, with
respect to an entity or asset, means that the entity
or asset would be excluded from an insolvent
entity’s estate in a receivership, insolvency or
similar proceeding.
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would find the arrangements to be legal,
valid, binding, and enforceable under
the law of the relevant jurisdiction.
If the criteria above are not met, a
clearing member client banking
organization must apply a risk weight of
4 percent to the trade exposure amount.
Under the final rule, as under the
proposal, for a cleared transaction with
a CCP that is not a QCCP, a clearing
member banking organization and a
clearing member client banking
organization must risk weight the trade
exposure amount to the CCP according
to the risk weight applicable to the CCP
under section 32 of the final rule
(generally, 100 percent). Collateral
posted by a clearing member banking
organization that is held by a custodian
in a manner that is bankruptcy remote
from the CCP is not subject to a capital
requirement for counterparty credit risk.
Similarly, collateral posted by a clearing
member client that is held by a
custodian in a manner that is
bankruptcy remote from the CCP,
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clearing member, and other clearing
member clients of the clearing member
is not be subject to a capital requirement
for counterparty credit risk.
The proposed rule was silent on the
risk weight that would apply where a
clearing member banking organization
acts for its own account or guarantees a
QCCP’s performance to a client.
Consistent with the BCBS CCP interim
framework, the final rule provides
additional specificity regarding the riskweighting methodologies for certain
exposures of clearing member banking
organizations. The final rule provides
that a clearing member banking
organization that (i) acts for its own
account, (ii) is acting as a financial
intermediary (with an offsetting
transaction or a guarantee of the client’s
performance to a QCCP), or (iii)
guarantees a QCCP’s performance to a
client would apply a two percent risk
weight to the banking organization’s
exposure to the QCCP. The diagrams
below demonstrate the various potential
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62101
transactions and exposure treatment in
the final rule. Table 21 sets out how the
transactions illustrated in the diagrams
below are risk-weighted under the final
rule.
In the diagram, ‘‘T’’ refers to a
transaction, and the arrow indicates the
direction of the exposure. The diagram
describes the appropriate risk weight
treatment for exposures from the
perspective of a clearing member
banking organization entering into
cleared transactions for its own account
(T1), a clearing member banking
organization entering into cleared
transactions on behalf of a client (T2
through T7), and a banking organization
entering into cleared transactions as a
client of a clearing member (T8 and T9).
Table 21 shows for each trade whom the
exposure is to, a description of the type
of trade, and the risk weight that would
apply based on the risk of the
counterparty.
BILLING CODE 4810–33–P
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BILLING CODE 4810–33–C
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TABLE 21—RISK WEIGHTS FOR VARIOUS CLEARED TRANSACTIONS
Exposure to
Description
......................
......................
......................
......................
......................
......................
......................
......................
QCCP ...............
Client ................
QCCP ...............
Client ................
QCCP ...............
Client ................
QCCP ...............
CM ....................
T9 ......................
QCCP ...............
Own account .............................................................
Financial intermediary with offsetting trade to QCCP
Financial intermediary with offsetting trade to QCCP
Agent with guarantee of client performance .............
Agent with guarantee of client performance .............
Guarantee of QCCP performance ............................
Guarantee of QCCP performance ............................
CM financial intermediary with offsetting trade to
QCCP.
CM agent with guarantee of client performance .......
T1
T2
T3
T4
T5
T6
T7
T8
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4. Default Fund Contribution Exposures
There are several risk mitigants
available when a party clears a
transaction through a CCP rather than
on a bilateral basis: The protection
provided to the CCP clearing members
by the margin requirements imposed by
the CCP; the CCP members’ default fund
contributions; and the CCP’s own
capital and contribution to the default
fund, which are an important source of
collateral in case of counterparty
default.165 CCPs independently
determine default fund contributions
that are required from members. The
BCBS therefore established, and the
final rule adopts, a risk-sensitive
approach for risk weighting a banking
organization’s exposure to a default
fund.
Under the proposed rule, there was
only one method that a clearing member
banking organization could use to
calculate its risk-weighted asset amount
for default fund contributions. The
BCBS CCP interim framework added a
second method to better reflect the
lower risks associated with exposures to
those clearinghouses that have relatively
large default funds with a significant
amount unfunded. Commenters
requested that the final rule adopt both
methods contained in the BCBS CCP
interim framework.
Accordingly, under the final rule, a
banking organization that is a clearing
member of a CCP must calculate the
risk-weighted asset amount for its
default fund contributions at least
quarterly or more frequently if there is
a material change, in the opinion of the
banking organization or the primary
Federal supervisor, in the financial
condition of the CCP. A default fund
contribution means the funds
contributed or commitments made by a
clearing member to a CCP’s mutualized
loss-sharing arrangement. If the CCP is
not a QCCP, the banking organization’s
risk-weighted asset amount for its
165 Default funds are also known as clearing
deposits or guaranty funds.
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Risk-weighting treatment under the final rule
2% risk weight on trade exposure amount.
OTC derivative with CEM scalar.**
2% risk weight on trade exposure amount.
OTC derivative with CEM scalar.**
No exposure.
OTC derivative with CEM scalar.**
2% risk weight on trade exposure amount.
2% or 4%* risk weight on trade exposure amount.
2% or 4%* risk weight on trade exposure amount.
default fund contribution is either the
sum of the default fund contributions
multiplied by 1,250 percent, or in cases
where the default fund contributions
may be unlimited, an amount as
determined by the banking
organization’s primary Federal
supervisor based on factors described
above.
Consistent with the BCBS CCP
interim framework, the final rule
requires a banking organization to
calculate a risk-weighted asset amount
for its default fund contribution using
one of two methods. Method one
requires a clearing member banking
organization to use a three-step process.
The first step is for the clearing member
banking organization to calculate the
QCCP’s hypothetical capital
requirement (KCCP), unless the QCCP
has already disclosed it, in which case
the banking organization must rely on
that disclosed figure, unless the banking
organization determines that a higher
figure is appropriate based on the
nature, structure, or characteristics of
the QCCP. KCCP is defined as the capital
that a QCCP is required to hold if it
were a banking organization, and is
calculated using the CEM for OTC
derivatives or the collateral haircut
approach for repo-style transactions,
recognizing the risk-mitigating effects of
collateral posted by and default fund
contributions received from the QCCP
clearing members.
The final rule provides several
modifications to the calculation of KCCP
to adjust for certain features that are
unique to QCCPs. Namely, the
modifications permit: (1) A clearing
member to offset its exposure to a QCCP
with actual default fund contributions,
and (2) greater recognition of netting
when using the CEM to calculate KCCP
described below. Additionally, the risk
weight of all clearing members is set at
20 percent, except when a banking
organization’s primary Federal
supervisor has determined that a higher
risk weight is appropriate based on the
specific characteristics of the QCCP and
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its clearing members. Finally, for
derivative contracts that are options, the
PFE amount calculation is adjusted by
multiplying the notional principal
amount of the derivative contract by the
appropriate conversion factor and the
absolute value of the option’s delta (that
is, the ratio of the change in the value
of the derivative contract to the
corresponding change in the price of the
underlying asset).
In the second step of method one, the
final rule requires a banking
organization to compare KCCP to the
funded portion of the default fund of a
QCCP, and to calculate the total of all
the clearing members’ capital
requirements (K*cm). If the total funded
default fund of a QCCP is less than
KCCP, the final rule requires additional
capital to be assessed against the
shortfall because of the small size of the
funded portion of the default fund
relative to KCCP. If the total funded
default fund of a QCCP is greater than
KCCP, but the QCCP’s own funded
contributions to the default fund are less
than KCCP (so that the clearing members’
default fund contributions are required
to achieve KCCP), the clearing members’
default fund contributions up to KCCP
are risk-weighted at 100 percent and a
decreasing capital factor, between 1.6
percent and 0.16 percent, is applied to
the clearing members’ funded default
fund contributions above KCCP. If the
QCCP’s own contribution to the default
fund is greater than KCCP, then only the
decreasing capital factor is applied to
the clearing members’ default fund
contributions.
In the third step of method one, the
final rule requires (K*cm) to be allocated
back to each individual clearing
member. This allocation is proportional
to each clearing member’s contribution
to the default fund but adjusted to
reflect the impact of two average-size
clearing members defaulting as well as
to account for the concentration of
exposures among clearing members. A
clearing member banking organization
multiplies its allocated capital
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requirement by 12.5 to determine its
risk-weighted asset amount for its
default fund contribution to the QCCP.
As the alternative, a banking
organization is permitted to use method
two, which is a simplified method
under which the risk-weighted asset
amount for its default fund contribution
to a QCCP equals 1,250 percent
multiplied by the default fund
contribution, subject to an overall cap.
The cap is based on a banking
organization’s trade exposure amount
for all of its transactions with a QCCP.
A banking organization’s risk-weighted
asset amount for its default fund
contribution to a QCCP is either a 1,250
percent risk weight applied to its default
fund contribution to that QCCP or 18
percent of its trade exposure amount to
that QCCP. Method two subjects a
banking organization to an overall cap
on the risk-weighted assets from all its
exposures to the CCP equal to 20
percent times the trade exposures to the
CCP. This 20 percent cap is arrived at
as the sum of the 2 percent capital
requirement for trade exposure plus 18
percent for the default fund portion of
a banking organization’s exposure to a
QCCP.
To address commenter concerns that
the CEM underestimates the multilateral
netting benefits arising from a QCCP,
the final rule recognizes the larger
diversification benefits inherent in a
multilateral netting arrangement for
purposes of measuring the QCCP’s
potential future exposure associated
with derivative contracts. Consistent
with the BCBS CCP interim framework,
and as mentioned above, the final rule
replaces the proposed factors (0.3 and
0.7) in the formula to calculate Anet
with 0.15 and 0.85, in sections
35(d)(3)(i)(A)(1) and 133(d)(3)(i)(A)(1) of
the final rule, respectively.
F. Credit Risk Mitigation
Banking organizations use a number
of techniques to mitigate credit risks.
For example, a banking organization
may collateralize exposures with cash or
securities; a third party may guarantee
an exposure; a banking organization
may buy a credit derivative to offset an
exposure’s credit risk; or a banking
organization may net exposures with a
counterparty under a netting agreement.
The general risk-based capital rules
recognize these techniques to some
extent. This section of the preamble
describes how the final rule allows
banking organizations to recognize the
risk-mitigation effects of guarantees,
credit derivatives, and collateral for
risk-based capital purposes. In general,
the final rule provides for a greater
variety of credit risk mitigation
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techniques than the general risk-based
capital rules.
Similar to the general risk-based
capital rules, under the final rule a
banking organization generally may use
a substitution approach to recognize the
credit risk mitigation effect of an eligible
guarantee from an eligible guarantor and
the simple approach to recognize the
effect of collateral. To recognize credit
risk mitigants, all banking organizations
must have operational procedures and
risk-management processes that ensure
that all documentation used in
collateralizing or guaranteeing a
transaction is legal, valid, binding, and
enforceable under applicable law in the
relevant jurisdictions. A banking
organization should conduct sufficient
legal review to reach a well-founded
conclusion that the documentation
meets this standard as well as conduct
additional reviews as necessary to
ensure continuing enforceability.
Although the use of credit risk
mitigants may reduce or transfer credit
risk, it simultaneously may increase
other risks, including operational,
liquidity, or market risk. Accordingly, a
banking organization should employ
robust procedures and processes to
control risks, including roll-off and
concentration risks, and monitor and
manage the implications of using credit
risk mitigants for the banking
organization’s overall credit risk profile.
1. Guarantees and Credit Derivatives
a. Eligibility Requirements
Consistent with the Basel capital
framework, the agencies and the FDIC
proposed to recognize a wider range of
eligible guarantors than permitted under
the general risk-based capital rules,
including sovereigns, the Bank for
International Settlements, the
International Monetary Fund, the
European Central Bank, the European
Commission, Federal Home Loan Banks
(FHLB), Federal Agricultural Mortgage
Corporation (Farmer Mac), MDBs,
depository institutions, BHCs, SLHCs,
credit unions, and foreign banks.
Eligible guarantors would also include
entities that are not special purpose
entities that have issued and
outstanding unsecured debt securities
without credit enhancement that are
investment grade and that meet certain
other requirements.166
166 Under the proposed and final rule, an
exposure is ‘‘investment grade’’ if the entity to
which the banking organization is exposed through
a loan or security, or the reference entity with
respect to a credit derivative, has adequate capacity
to meet financial commitments for the projected life
of the asset or exposure. Such an entity or reference
entity has adequate capacity to meet financial
commitments if the risk of its default is low and the
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Some commenters suggested
modifying the proposed definition of
eligible guarantor to remove the
investment-grade requirement.
Commenters also suggested that the
agencies and the FDIC potentially
include as eligible guarantors other
entities, such as financial guaranty and
private mortgage insurers. The agencies
believe that guarantees issued by these
types of entities can exhibit significant
wrong-way risk and modifying the
definition of eligible guarantor to
accommodate these entities or entities
that are not investment grade would be
contrary to one of the key objectives of
the capital framework, which is to
mitigate interconnectedness and
systemic vulnerabilities within the
financial system. Therefore, the agencies
have not included the recommended
entities in the final rule’s definition of
‘‘eligible guarantor.’’ The agencies have,
however, amended the definition of
eligible guarantor in the final rule to
include QCCPs to accommodate use of
the substitution approach for credit
derivatives that are cleared transactions.
The agencies believe that QCCPs, as
supervised entities subject to specific
risk-management standards, are
appropriately included as eligible
guarantors under the final rule.167 In
addition, the agencies clarify one
commenter’s concern and confirm that
re-insurers that are engaged
predominantly in the business of
providing credit protection do not
qualify as an eligible guarantor under
the final rule.
Under the final rule, guarantees and
credit derivatives are required to meet
specific eligibility requirements to be
recognized for credit risk mitigation
purposes. Consistent with the proposal,
under the final rule, an eligible
guarantee is defined as a guarantee from
an eligible guarantor that is written and
meets certain standards and conditions,
including with respect to its
enforceability. An eligible credit
derivative is defined as a credit
derivative in the form of a CDS, nth-todefault swap, total return swap, or any
other form of credit derivative approved
by the primary Federal supervisor,
provided that the instrument meets the
standards and conditions set forth in the
definition. See the definitions of
‘‘eligible guarantee’’ and ‘‘eligible credit
derivative’’ in section 2 of the final rule.
Under the proposal, a banking
organization would have been permitted
to recognize the credit risk mitigation
full and timely repayment of principal and interest
is expected.
167 See the definition of ‘‘eligible guarantor’’ in
section 2 of the final rule.
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benefits of an eligible credit derivative
that hedges an exposure that is different
from the credit derivative’s reference
exposure used for determining the
derivative’s cash settlement value,
deliverable obligation, or occurrence of
a credit event if (1) the reference
exposure ranks pari passu with or is
subordinated to the hedged exposure;
(2) the reference exposure and the
hedged exposure are to the same legal
entity; and (3) legally-enforceable crossdefault or cross-acceleration clauses are
in place to assure payments under the
credit derivative are triggered when the
issuer fails to pay under the terms of the
hedged exposure.
In addition to these two exceptions,
one commenter encouraged the agencies
and the FDIC to revise the final rule to
recognize a proxy hedge as an eligible
credit derivative even though such a
transaction hedges an exposure that
differs from the credit derivative’s
reference exposure. A proxy hedge was
characterized by the commenter as a
hedge of an exposure supported by a
sovereign using a credit derivative on
that sovereign. The agencies do not
believe there is sufficient justification to
include proxy hedges in the definition
of eligible credit derivative because they
have concerns regarding the ability of
the hedge to sufficiently mitigate the
risk of the underlying exposure. The
agencies have, therefore, adopted the
definition of eligible credit derivative as
proposed.
In addition, under the final rule,
consistent with the proposal, when a
banking organization has a group of
hedged exposures with different
residual maturities that are covered by
a single eligible guarantee or eligible
credit derivative, it must treat each
hedged exposure as if it were fully
covered by a separate eligible guarantee
or eligible credit derivative.
b. Substitution Approach
The agencies are adopting the
substitution approach for eligible
guarantees and eligible credit
derivatives in the final rule without
change. Under the substitution
approach, if the protection amount (as
defined below) of an eligible guarantee
or eligible credit derivative is greater
than or equal to the exposure amount of
the hedged exposure, a banking
organization substitutes the risk weight
applicable to the guarantor or credit
derivative protection provider for the
risk weight applicable to the hedged
exposure.
If the protection amount of the
eligible guarantee or eligible credit
derivative is less than the exposure
amount of the hedged exposure, a
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banking organization must treat the
hedged exposure as two separate
exposures (protected and unprotected)
to recognize the credit risk mitigation
benefit of the guarantee or credit
derivative. In such cases, a banking
organization calculates the riskweighted asset amount for the protected
exposure under section 36 of the final
rule (using a risk weight applicable to
the guarantor or credit derivative
protection provider and an exposure
amount equal to the protection amount
of the guarantee or credit derivative).
The banking organization calculates its
risk-weighted asset amount for the
unprotected exposure under section 32
of the final rule (using the risk weight
assigned to the exposure and an
exposure amount equal to the exposure
amount of the original hedged exposure
minus the protection amount of the
guarantee or credit derivative).
Under the final rule, the protection
amount of an eligible guarantee or
eligible credit derivative means the
effective notional amount of the
guarantee or credit derivative reduced to
reflect any, maturity mismatch, lack of
restructuring coverage, or currency
mismatch as described below. The
effective notional amount for an eligible
guarantee or eligible credit derivative is
the lesser of the contractual notional
amount of the credit risk mitigant and
the exposure amount of the hedged
exposure, multiplied by the percentage
coverage of the credit risk mitigant. For
example, the effective notional amount
of a guarantee that covers, on a pro rata
basis, 40 percent of any losses on a $100
bond is $40.
c. Maturity Mismatch Haircut
The agencies are adopting the
proposed haircut for maturity mismatch
in the final rule without change. Under
the final rule, the agencies have adopted
the requirement that a banking
organization that recognizes an eligible
guarantee or eligible credit derivative
must adjust the effective notional
amount of the credit risk mitigant to
reflect any maturity mismatch between
the hedged exposure and the credit risk
mitigant. A maturity mismatch occurs
when the residual maturity of a credit
risk mitigant is less than that of the
hedged exposure(s).168
168 As noted above, when a banking organization
has a group of hedged exposures with different
residual maturities that are covered by a single
eligible guarantee or eligible credit derivative, a
banking organization treats each hedged exposure
as if it were fully covered by a separate eligible
guarantee or eligible credit derivative. To determine
whether any of the hedged exposures has a maturity
mismatch with the eligible guarantee or credit
derivative, the banking organization assesses
whether the residual maturity of the eligible
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The residual maturity of a hedged
exposure is the longest possible
remaining time before the obligated
party of the hedged exposure is
scheduled to fulfil its obligation on the
hedged exposure. A banking
organization is required to take into
account any embedded options that may
reduce the term of the credit risk
mitigant so that the shortest possible
residual maturity for the credit risk
mitigant is used to determine the
potential maturity mismatch. If a call is
at the discretion of the protection
provider, the residual maturity of the
credit risk mitigant is at the first call
date. If the call is at the discretion of the
banking organization purchasing the
protection, but the terms of the
arrangement at origination of the credit
risk mitigant contain a positive
incentive for the banking organization to
call the transaction before contractual
maturity, the remaining time to the first
call date is the residual maturity of the
credit risk mitigant. A banking
organization is permitted, under the
final rule, to recognize a credit risk
mitigant with a maturity mismatch only
if its original maturity is greater than or
equal to one year and the residual
maturity is greater than three months.
Assuming that the credit risk mitigant
may be recognized, a banking
organization is required to apply the
following adjustment to reduce the
effective notional amount of the credit
risk mitigant to recognize the maturity
mismatch:
Pm = E × [(t¥0.25)/(T¥0.25)],
where:
(1) Pm = effective notional amount of the
credit risk mitigant, adjusted for maturity
mismatch;
(2) E = effective notional amount of the credit
risk mitigant;
(3) t = the lesser of T or residual maturity of
the credit risk mitigant, expressed in
years; and
(4) T = the lesser of five or the residual
maturity of the hedged exposure,
expressed in years.
d. Adjustment for Credit Derivatives
Without Restructuring as a Credit Event
The agencies are adopting in the final
rule the proposed adjustment for credit
derivatives without restructuring as a
credit event. Consistent with the
proposal, under the final rule, a banking
organization that seeks to recognize an
eligible credit derivative that does not
include a restructuring of the hedged
exposure as a credit event under the
derivative must reduce the effective
notional amount of the credit derivative
guarantee or eligible credit derivative is less than
that of the hedged exposure.
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recognized for credit risk mitigation
purposes by 40 percent. For purposes of
the credit risk mitigation framework, a
restructuring may involve forgiveness or
postponement of principal, interest, or
fees that result in a credit loss event
(that is, a charge-off, specific provision,
or other similar debit to the profit and
loss account). In these instances, the
banking organization is required to
apply the following adjustment to
reduce the effective notional amount of
the credit derivative:
Pr = Pm × 0.60,
where:
(1) Pr = effective notional amount of the
credit risk mitigant, adjusted for lack of
a restructuring event (and maturity
mismatch, if applicable); and
(2) Pm = effective notional amount of the
credit risk mitigant (adjusted for
maturity mismatch, if applicable).
e. Currency Mismatch Adjustment
Consistent with the proposal, under
the final rule, if a banking organization
recognizes an eligible guarantee or
eligible credit derivative that is
denominated in a currency different
from that in which the hedged exposure
is denominated, the banking
organization must apply the following
formula to the effective notional amount
of the guarantee or credit derivative:
PC = Pr × (1¥HFX),
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where:
(1) Pc = effective notional amount of the
credit risk mitigant, adjusted for
currency mismatch (and maturity
mismatch and lack of restructuring
event, if applicable);
(2) Pr = effective notional amount of the
credit risk mitigant (adjusted for
maturity mismatch and lack of
restructuring event, if applicable); and
(3) HFX = haircut appropriate for the currency
mismatch between the credit risk
mitigant and the hedged exposure.
A banking organization is required to
use a standard supervisory haircut of 8
percent for HFX (based on a tenbusiness-day holding period and daily
marking-to-market and remargining).
Alternatively, a banking organization
has the option to use internally
estimated haircuts of HFX based on a
ten-business-day holding period and
daily marking-to-market if the banking
organization qualifies to use the ownestimates of haircuts in section 37(c)(4)
of the final rule. In either case, the
banking organization is required to scale
the haircuts up using the square root of
time formula if the banking organization
revalues the guarantee or credit
derivative less frequently than once
every 10 business days. The applicable
haircut (HM) is calculated using the
following square root of time formula:
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where:
TM = equals the greater of 10 or the number
of days between revaluation.
f. Multiple Credit Risk Mitigants
Consistent with the proposal, under
the final rule, if multiple credit risk
mitigants cover a single exposure, a
banking organization may disaggregate
the exposure into portions covered by
each credit risk mitigant (for example,
the portion covered by each guarantee)
and calculate separately a risk-based
capital requirement for each portion,
consistent with the Basel capital
framework. In addition, when a single
credit risk mitigant covers multiple
exposures, a banking organization must
treat each hedged exposure as covered
by a single credit risk mitigant and must
calculate separate risk-weighted asset
amounts for each exposure using the
substitution approach described in
section 36(c) of the final rule.
2. Collateralized Transactions
a. Eligible Collateral
Under the proposal, the agencies and
the FDIC would recognize an expanded
range of financial collateral as credit
risk mitigants that may reduce the riskbased capital requirements associated
with a collateralized transaction,
consistent with the Basel capital
framework. The agencies and the FDIC
proposed that a banking organization
could recognize the risk-mitigating
effects of financial collateral using the
‘‘simple approach’’ for any exposure
provided that the collateral meets
certain requirements. For repo-style
transactions, eligible margin loans,
collateralized derivative contracts, and
single-product netting sets of such
transactions, a banking organization
could alternatively use the collateral
haircut approach. The proposal required
a banking organization to use the same
approach for similar exposures or
transactions.
The commenters generally agreed
with this aspect of the proposal;
however, a few commenters encouraged
the agencies and the FDIC to expand the
definition of financial collateral to
include precious metals and certain
residential mortgages that collateralize
warehouse lines of credit. Several
commenters asserted that the final rule
should recognize as financial collateral
conforming residential mortgages (or at
least those collateralizing warehouse
lines of credit) and/or those insured by
the FHA or VA. They noted that by not
including conforming residential
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mortgages in the definition of financial
collateral, the proposed rule would
require banking organizations providing
warehouse lines to treat warehouse
facilities as commercial loan exposures,
thus preventing such entities from
looking through to the underlying
collateral in calculating the appropriate
risk weighting. Others argued that a
‘‘look through’’ approach for a repostyle structure to the financial collateral
held therein should be allowed. Another
commenter argued that the final rule
should allow recognition of intangible
assets as financial collateral because
they have real value. The agencies
believe that the collateral types
suggested by the commenters are not
appropriate forms of financial collateral
because they exhibit increased variation
and credit risk, and are relatively more
speculative than the recognized forms of
financial collateral under the proposal.
For example, residential mortgages can
be highly idiosyncratic in regards to
payment features, interest rate
provisions, lien seniority, and
maturities. The agencies believe that the
proposed definition of financial
collateral, which is broader than the
collateral recognized under the general
risk-based capital rules, included those
collateral types of sufficient liquidity
and asset quality to recognize as credit
risk mitigants for risk-based capital
purposes. As a result, the agencies have
retained the definition of financial
collateral as proposed. Therefore,
consistent with the proposal, the final
rule defines financial collateral as
collateral in the form of: (1) Cash on
deposit with the banking organization
(including cash held for the banking
organization by a third-party custodian
or trustee); (2) gold bullion; (3) shortand long-term debt securities that are
not resecuritization exposures and that
are investment grade; (4) equity
securities that are publicly-traded; (5)
convertible bonds that are publiclytraded; or (6) money market fund shares
and other mutual fund shares if a price
for the shares is publicly quoted daily.
With the exception of cash on deposit,
the banking organization is also
required to have a perfected, firstpriority security interest or, outside of
the United States, the legal equivalent
thereof, notwithstanding the prior
security interest of any custodial agent.
Even if a banking organization has the
legal right, it still must ensure it
monitors or has a freeze on the account
to prevent a customer from withdrawing
cash on deposit prior to defaulting. A
banking organization is permitted to
recognize partial collateralization of an
exposure.
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Under the final rule, the agencies
require that a banking organization
could recognize the risk-mitigating
effects of financial collateral using the
simple approach described below,
where: The collateral is subject to a
collateral agreement for at least the life
of the exposure; the collateral is
revalued at least every six months; and
the collateral (other than gold) and the
exposure is denominated in the same
currency. For repo-style transactions,
eligible margin loans, collateralized
derivative contracts, and single-product
netting sets of such transactions, a
banking organization could alternatively
use the collateral haircut approach
described below. The final rule, like the
proposal, requires a banking
organization to use the same approach
for similar exposures or transactions.
b. Risk-Management Guidance for
Recognizing Collateral
Before a banking organization
recognizes collateral for credit risk
mitigation purposes, it should: (1)
Conduct sufficient legal review to
ensure, at the inception of the
collateralized transaction and on an
ongoing basis, that all documentation
used in the transaction is binding on all
parties and legally enforceable in all
relevant jurisdictions; (2) consider the
correlation between risk of the
underlying direct exposure and
collateral in the transaction; and (3)
fully take into account the time and cost
needed to realize the liquidation
proceeds and the potential for a decline
in collateral value over this time period.
A banking organization also should
ensure that the legal mechanism under
which the collateral is pledged or
transferred ensures that the banking
organization has the right to liquidate or
take legal possession of the collateral in
a timely manner in the event of the
default, insolvency, or bankruptcy (or
other defined credit event) of the
counterparty and, where applicable, the
custodian holding the collateral.
In addition, a banking organization
should ensure that it (1) has taken all
steps necessary to fulfill any legal
requirements to secure its interest in the
collateral so that it has and maintains an
enforceable security interest; (2) has set
up clear and robust procedures to
ensure satisfaction of any legal
conditions required for declaring the
default of the borrower and prompt
liquidation of the collateral in the event
of default; (3) has established
procedures and practices for
conservatively estimating, on a regular
ongoing basis, the fair value of the
collateral, taking into account factors
that could affect that value (for example,
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the liquidity of the market for the
collateral and obsolescence or
deterioration of the collateral); and (4)
has in place systems for promptly
requesting and receiving additional
collateral for transactions whose terms
require maintenance of collateral values
at specified thresholds.
c. Simple Approach
The agencies are adopting the simple
approach without change for purposes
of the final rule. Under the final rule,
the collateralized portion of the
exposure receives the risk weight
applicable to the collateral. The
collateral is required to meet the
definition of financial collateral. For
repurchase agreements, reverse
repurchase agreements, and securities
lending and borrowing transactions, the
collateral would be the instruments,
gold, and cash that a banking
organization has borrowed, purchased
subject to resale, or taken as collateral
from the counterparty under the
transaction. As noted above, in all cases,
(1) the collateral must be subject to a
collateral agreement for at least the life
of the exposure; (2) the banking
organization must revalue the collateral
at least every six months; and (3) the
collateral (other than gold) and the
exposure must be denominated in the
same currency.
Generally, the risk weight assigned to
the collateralized portion of the
exposure must be no less than 20
percent. However, the collateralized
portion of an exposure may be assigned
a risk weight of less than 20 percent for
the following exposures. OTC derivative
contracts that are marked to fair value
on a daily basis and subject to a daily
margin maintenance agreement, may
receive (1) a zero percent risk weight to
the extent that contracts are
collateralized by cash on deposit, or (2)
a 10 percent risk weight to the extent
that the contracts are collateralized by
an exposure to a sovereign that qualifies
for a zero percent risk weight under
section 32 of the final rule. In addition,
a banking organization may assign a
zero percent risk weight to the
collateralized portion of an exposure
where the financial collateral is cash on
deposit; or the financial collateral is an
exposure to a sovereign that qualifies for
a zero percent risk weight under section
32 of the final rule, and the banking
organization has discounted the fair
value of the collateral by 20 percent.
d. Collateral Haircut Approach
Consistent with the proposal, in the
final rule, a banking organization may
use the collateral haircut approach to
recognize the credit risk mitigation
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62107
benefits of financial collateral that
secures an eligible margin loan, repostyle transaction, collateralized
derivative contract, or single-product
netting set of such transactions. In
addition, the banking organization may
use the collateral haircut approach with
respect to any collateral that secures a
repo-style transaction that is included in
the banking organization’s VaR-based
measure under subpart F of the final
rule, even if the collateral does not meet
the definition of financial collateral.
To apply the collateral haircut
approach, a banking organization must
determine the exposure amount and the
relevant risk weight for the counterparty
or guarantor.
The exposure amount for an eligible
margin loan, repo-style transaction,
collateralized derivative contract, or a
netting set of such transactions is equal
to the greater of zero and the sum of the
following three quantities:
(1) The value of the exposure less the
value of the collateral. For eligible
margin loans, repo-style transactions
and netting sets thereof, the value of the
exposure is the sum of the current
market values of all instruments, gold,
and cash the banking organization has
lent, sold subject to repurchase, or
posted as collateral to the counterparty
under the transaction or netting set. For
collateralized OTC derivative contracts
and netting sets thereof, the value of the
exposure is the exposure amount that is
calculated under section 34 of the final
rule. The value of the collateral equals
the sum of the current market values of
all instruments, gold and cash the
banking organization has borrowed,
purchased subject to resale, or taken as
collateral from the counterparty under
the transaction or netting set;
(2) The absolute value of the net
position in a given instrument or in gold
(where the net position in a given
instrument or in gold equals the sum of
the current market values of the
instrument or gold the banking
organization has lent, sold subject to
repurchase, or posted as collateral to the
counterparty minus the sum of the
current market values of that same
instrument or gold that the banking
organization has borrowed, purchased
subject to resale, or taken as collateral
from the counterparty) multiplied by the
market price volatility haircut
appropriate to the instrument or gold;
and
(3) The absolute value of the net
position of instruments and cash in a
currency that is different from the
settlement currency (where the net
position in a given currency equals the
sum of the current market values of any
instruments or cash in the currency the
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banking organization has lent, sold
subject to repurchase, or posted as
collateral to the counterparty minus the
sum of the current market values of any
instruments or cash in the currency the
banking organization has borrowed,
purchased subject to resale, or taken as
collateral from the counterparty)
multiplied by the haircut appropriate to
the currency mismatch.
For purposes of the collateral haircut
approach, a given instrument includes,
for example, all securities with a single
Committee on Uniform Securities
Identification Procedures (CUSIP)
number and would not include
securities with different CUSIP
numbers, even if issued by the same
issuer with the same maturity date.
e. Standard Supervisory Haircuts
When determining the exposure
amount, the banking organization must
apply a haircut for price market
volatility and foreign exchange rates,
determined either using standard
supervisory market price volatility
haircuts and a standard haircut for
exchange rates or, with prior approval of
the agency, a banking organization’s
own estimates of volatilities of market
prices and foreign exchange rates.
The standard supervisory market
price volatility haircuts set a specified
market price volatility haircut for
various categories of financial collateral.
These standard haircuts are based on
the ten-business-day holding period for
eligible margin loans and derivative
contracts. For repo-style transactions, a
banking organization may multiply the
standard supervisory haircuts by the
square root of 1⁄2 to scale them for a
holding period of five business days.
Several commenters argued that the
proposed haircuts were too conservative
and insufficiently risk-sensitive, and
that banking organizations should be
allowed to compute their own haircuts.
Some commenters proposed limiting the
maximum haircut for non-sovereign
issuers that receive a 100 percent risk
weight to 12 percent and, more
specifically, assigning a lower haircut
than 25 percent for financial collateral
in the form of an investment-grade
corporate debt security that has a
shorter residual maturity. The
commenters asserted that these haircuts
conservatively correspond to the
existing rating categories and result in
greater alignment with the Basel
framework.
In the final rule, the agencies have
revised from 25.0 percent the standard
supervisory market price volatility
haircuts for financial collateral issued
by non-sovereign issuers with a risk
weight of 100 percent to 4.0 percent for
maturities of less than one year, 8.0
percent for maturities greater than one
year but less than or equal to five years,
and 16.0 percent for maturities greater
than five years, consistent with Table 22
below. The agencies believe that the
revised haircuts better reflect the
collateral’s credit quality and an
appropriate differentiation based on the
collateral’s residual maturity.
A banking organization using the
standard currency mismatch haircut is
required to use an 8 percent haircut for
each currency mismatch for transactions
subject to a 10 day holding period, as
adjusted for different required holding
periods. One commenter asserted that
the proposed adjustment for currency
mismatch was unwarranted because in
securities lending transactions, the
parties typically require a higher
collateral margin than in transactions
where there is no mismatch. In the
alternative, the commenter argued that
the agencies and the FDIC should align
the currency mismatch haircut more
closely with a given currency
combination and suggested those
currencies of countries with a more
favorable CRC from the OECD should
receive a smaller haircut. The agencies
have decided to adopt this aspect of the
proposal without change in the final
rule. The agencies believe that the own
internal estimates for haircuts
methodology described below allows
banking organizations appropriate
flexibility to more granularly reflect
individual currency combinations,
provided they meet certain criteria.
TABLE 22—STANDARD SUPERVISORY MARKET PRICE VOLATILITY HAIRCUTS 1
Haircut (in percent) assigned based on:
Sovereign issuers risk weight
under § l.32 2
Residual maturity
Zero
Less than or equal to 1 year .....................
Greater than 1 year and less than or
equal to 5 years .....................................
Greater than 5 years ..................................
20 or 50
Non-sovereign issuers risk weight
under § l.32
100
20
50
Investment-grade
securitization
exposures
(in percent)
100
0.5
1.0
15.0
1.0
2.0
4.0
4.0
2.0
4.0
3.0
6.0
15.0
15.0
4.0
8.0
6.0
12.0
8.0
16.0
12.0
24.0
Main index equities (including convertible bonds) and gold .......................................
15.0
Other publicly-traded equities (including convertible bonds) .......................................
25.0
Mutual funds ................................................................................................................
Highest haircut applicable to any security in which the fund
can invest.
Cash collateral held .....................................................................................................
Zero
Other exposure types ..................................................................................................
25.0
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1 The
market price volatility haircuts in Table 22 are based on a 10 business-day holding period.
2 Includes a foreign PSE that receives a zero percent risk weight.
The final rule requires that a banking
organization increase the standard
supervisory haircut for transactions
involving large netting sets. As noted in
the proposed rule, during the recent
financial crisis, many financial
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institutions experienced significant
delays in settling or closing-out
collateralized transactions, such as repostyle transactions and collateralized
OTC derivatives. The assumed holding
period for collateral in the collateral
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haircut approach under Basel II proved
to be inadequate for certain transactions
and netting sets and did not reflect the
difficulties and delays that institutions
had when settling or liquidating
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collateral during a period of financial
stress.
Thus, consistent with the proposed
rule, for netting sets where: (1) The
number of trades exceeds 5,000 at any
time during the quarter; (2) one or more
trades involves illiquid collateral posted
by the counterparty; or (3) the netting
set includes any OTC derivatives that
cannot be easily replaced, the final rule
requires a banking organization to
assume a holding period of 20 business
days for the collateral under the
collateral haircut approach. The formula
and methodology for increasing the
haircut to reflect the longer holding
period is described in section 37(c) of
the final rule. Consistent with the Basel
capital framework, a banking
organization is not required to adjust the
holding period upward for cleared
transactions. When determining
whether collateral is illiquid or whether
an OTC derivative cannot be easily
replaced for these purposes, a banking
organization should assess whether,
during a period of stressed market
conditions, it could obtain multiple
price quotes within two days or less for
the collateral or OTC derivative that
would not move the market or represent
a market discount (in the case of
collateral) or a premium (in the case of
an OTC derivative).
One commenter requested the
agencies and the FDIC clarify whether
the 5,000-trade threshold applies on a
counterparty-by-counterparty (rather
than aggregate) basis, and only will be
triggered in the event there are 5,000
open trades with a single counterparty
within a single netting set in a given
quarter. Commenters also asked whether
the threshold would be calculated on an
average basis or whether a de minimis
number of breaches could be permitted
without triggering the increased holding
period or margin period of risk. One
commenter suggested eliminating the
threshold because it is ineffective as a
measure of risk, and combined with
other features of the proposals (for
example, collateral haircuts, margin
disputes), could create a disincentive for
banking organizations to apply sound
practices such as risk diversification.
The agencies note that the 5,000-trade
threshold applies to a netting set, which
by definition means a group of
transactions with a single counterparty
that are subject to a qualifying master
netting agreement. The 5,000 trade
calculation threshold was proposed as
an indicator that a set of transactions
may be more complex, or require a
lengthy period, to close out in the event
of a default of a counterparty. The
agencies continue to believe that the
threshold of 5,000 is a reasonable
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indicator of the complexity of a closeout. Therefore, the final rule retains the
5,000 trade threshold as proposed,
without any de minimis exception.
One commenter asked the agencies to
clarify how trades would be counted in
the context of an indemnified agency
securities lending relationship. In such
transactions, an agent banking
organization acts as an intermediary for,
potentially, multiple borrowers and
lenders. The banking organization is
acting as an agent with no exposure to
either the securities lenders or
borrowers except for an indemnification
to the securities lenders in the event of
a borrower default. The indemnification
creates an exposure to the securities
borrower, as the agent banking
organization could suffer a loss upon
the default of a borrower. In these cases,
each transaction between the agent and
a borrower would count as a trade. The
agencies note that a trade in this
instance consists of an order by the
borrower, and not the number of
securities lenders providing shares to
fulfil the order or the number of shares
underlying such order.169
The commenters also addressed the
longer holding period for trades
involving illiquid collateral posted by
the counterparty. Some commenters
asserted that one illiquid exposure or
one illiquid piece of collateral should
not taint the entire netting set. Other
commenters recommended applying a
materiality threshold (for example, 1
percent) below which one or more
illiquid exposures would not trigger the
longer holding period, or allowing
banking organizations to define
‘‘materiality’’ based on experience.
Regarding the potential for an illiquid
exposure to ‘‘taint’’ an entire netting set,
the final rule does not require a banking
organization to recognize any piece of
collateral as a risk mitigant.
Accordingly, if a banking organization
elects to exclude the illiquid collateral
from the netting set for purposes of
calculating risk-weighted assets, then
such illiquid collateral does not result
in an increased holding period for the
netting set. With respect to a derivative
that may not be easily replaced, a
banking organization could create a
separate netting set that would preserve
the holding period for the original
netting set of easily replaced
transactions. Accordingly, the final rule
169 In the event that the agent banking
organization reinvests the cash collateral proceeds
on behalf of the lender and provides an explicit or
implicit guarantee of the value of the collateral in
such pool, the banking organization should hold
capital, as appropriate, against the risk of loss of
value of the collateral pool.
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adopts this aspect of the proposal
without change.
One commenter asserted that the final
rule should not require a banking
organization to determine whether an
instrument is liquid on a daily basis, but
rather should base the timing of such
determination by product category and
on long-term liquidity data. According
to the commenter, such an approach
would avoid potential confusion,
volatility and destabilization of the
funding markets. For purposes of
determining whether collateral is
illiquid or an OTC derivative contract is
easily replaceable under the final rule,
a banking organization may assess
whether, during a period of stressed
market conditions, it could obtain
multiple price quotes within two days
or less for the collateral or OTC
derivative that would not move the
market or represent a market discount
(in the case of collateral) or a premium
(in the case of an OTC derivative). A
banking organization is not required to
make a daily determination of liquidity
under the final rule; rather, banking
organizations should have policies and
procedures in place to evaluate the
liquidity of their collateral as frequently
as warranted.
Under the proposed rule, a banking
organization would increase the holding
period for a netting set if over the two
previous quarters more than two margin
disputes on a netting set have occurred
that lasted longer than the holding
period. However, consistent with the
Basel capital framework, a banking
organization would not be required to
adjust the holding period upward for
cleared transactions. Several
commenters requested further
clarification on the meaning of ‘‘margin
disputes.’’ Some of these commenters
suggested restricting ‘‘margin disputes’’
to formal legal action. Commenters also
suggested restricting ‘‘margin disputes’’
to disputes resulting in the creation of
an exposure that exceeded any available
overcollateralization, or establishing a
materiality threshold. One commenter
suggested that margin disputes were not
an indicator of an increased risk and,
therefore, should not trigger a longer
holding period.
The agencies continue to believe that
an increased holding period is
appropriate regardless of whether the
dispute exceeds applicable collateral
requirements and regardless of whether
the disputes exceed a materiality
threshold. The agencies expect that the
determination as to whether a dispute
constitutes a margin dispute for
purposes of the final rule will depend
solely on the timing of the resolution.
That is to say, if collateral is not
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delivered within the time period
required under an agreement, and such
failure to deliver is not resolved in a
timely manner, then such failure would
count toward the two-margin-dispute
limit. For the purpose of the final rule,
where a dispute is subject to a
recognized industry dispute resolution
protocol, the agencies expect to consider
the dispute period to begin after a thirdparty dispute resolution mechanism has
failed.
For comments and concerns that are
specific to the parallel provisions in the
advanced approaches rule, reference
section XII.A of this preamble.
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f. Own Estimates of Haircuts
Under the final rule, consistent with
the proposal, banking organizations may
calculate market price volatility and
foreign exchange volatility using own
internal estimates with prior written
approval of the banking organization’s
primary Federal supervisor. To receive
approval to calculate haircuts using its
own internal estimates, a banking
organization must meet certain
minimum qualitative and quantitative
standards set forth in the final rule,
including the requirements that a
banking organization: (1) Uses a 99th
percentile one-tailed confidence interval
and a minimum five-business-day
holding period for repo-style
transactions and a minimum tenbusiness-day holding period for all
other transactions; (2) adjusts holding
periods upward where and as
appropriate to take into account the
illiquidity of an instrument; (3) selects
a historical observation period that
reflects a continuous 12-month period
of significant financial stress
appropriate to the banking
organization’s current portfolio; and (4)
updates its data sets and compute
haircuts no less frequently than
quarterly, as well as any time market
prices change materially. A banking
organization estimates the volatilities of
exposures, the collateral, and foreign
exchange rates and should not take into
account the correlations between them.
The final rule provides a formula for
converting own-estimates of haircuts
based on a holding period different from
the minimum holding period under the
rule to haircuts consistent with the
rule’s minimum holding periods. The
minimum holding periods for netting
sets with more than 5,000 trades, netting
sets involving illiquid collateral or an
OTC derivative that cannot easily be
replaced, and netting sets involving
more than two margin disputes over the
previous two quarters described above
also apply for own-estimates of haircuts.
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Under the final rule, a banking
organization is required to have policies
and procedures that describe how it
determines the period of significant
financial stress used to calculate the
banking organization’s own internal
estimates, and to be able to provide
empirical support for the period used.
These policies and procedures must
address (1) how the banking
organization links the period of
significant financial stress used to
calculate the own internal estimates to
the composition and directional bias of
the banking organization’s current
portfolio; and (2) the banking
organization’s process for selecting,
reviewing, and updating the period of
significant financial stress used to
calculate the own internal estimates and
for monitoring the appropriateness of
the 12-month period in light of the
banking organization’s current portfolio.
The banking organization is required to
obtain the prior approval of its primary
Federal supervisor for these policies and
procedures and notify its primary
Federal supervisor if the banking
organization makes any material
changes to them. A banking
organization’s primary Federal
supervisor may require it to use a
different period of significant financial
stress in the calculation of the banking
organization’s own internal estimates.
Under the final rule, a banking
organization is allowed to calculate
internally estimated haircuts for
categories of debt securities that are
investment-grade exposures. The
haircut for a category of securities must
be representative of the internal
volatility estimates for securities in that
category that the banking organization
has lent, sold subject to repurchase,
posted as collateral, borrowed,
purchased subject to resale, or taken as
collateral. In determining relevant
categories, the banking organization
must, at a minimum, take into account
(1) the type of issuer of the security; (2)
the credit quality of the security; (3) the
maturity of the security; and (4) the
interest rate sensitivity of the security.
A banking organization must calculate
a separate internally estimated haircut
for each individual non-investmentgrade debt security and for each
individual equity security. In addition,
a banking organization must estimate a
separate currency mismatch haircut for
its net position in each mismatched
currency based on estimated volatilities
for foreign exchange rates between the
mismatched currency and the
settlement currency where an exposure
or collateral (whether in the form of
cash or securities) is denominated in a
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currency that differs from the settlement
currency.
g. Simple Value-at-Risk and Internal
Models Methodology
In the NPR, the agencies and the FDIC
did not propose a simple VaR approach
to calculate exposure amounts for
eligible margin loans and repo-style
transactions or IMM to calculate the
exposure amount for the counterparty
credit exposure for OTC derivatives,
eligible margin loans, and repo-style
transactions. These methodologies are
included in the advanced approaches
rule. The agencies and the FDIC sought
comment on whether to implement the
simple VaR approach and IMM in the
standardized approach. Several
commenters asserted that the IMM and
simple VaR approach should be
implemented in the final rule to better
capture the risk of counterparty credit
exposures. The agencies have
considered these comments and, have
concluded that the increased
complexity and limited applicability of
these models-based approaches is
inconsistent with the agencies’ overall
focus in the standardized approach on
simplicity, comparability, and broad
applicability of methodologies for U.S.
banking organizations. Therefore,
consistent with the proposal, the final
rule does not include the simple VaR
approach or the IMM in the
standardized approach.
G. Unsettled Transactions
Under the proposed rule, a banking
organization would be required to hold
capital against the risk of certain
unsettled transactions. One commenter
expressed opposition to assigning a risk
weight to unsettled transactions where
previously none existed, because it
would require a significant and
burdensome tracking process without
commensurate benefit. The agencies
believe that it is important for a banking
organization to have procedures to
identify and track a delayed or unsettled
transaction of the types specified in the
rule. Such procedures capture the
resulting risks associated with such
delay. As a result, the agencies are
adopting the risk-weighting
requirements as proposed.
Consistent with the proposal, the final
rule provides for a separate risk-based
capital requirement for transactions
involving securities, foreign exchange
instruments, and commodities that have
a risk of delayed settlement or delivery.
Under the final rule, the capital
requirement does not, however, apply to
certain types of transactions, including:
(1) Cleared transactions that are markedto-market daily and subject to daily
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receipt and payment of variation
margin; (2) repo-style transactions,
including unsettled repo-style
transactions; (3) one-way cash payments
on OTC derivative contracts; or (4)
transactions with a contractual
settlement period that is longer than the
normal settlement period (which the
proposal defined as the lesser of the
market standard for the particular
instrument or five business days).170 In
the case of a system-wide failure of a
settlement, clearing system, or central
counterparty, the banking organization’s
primary Federal supervisor may waive
risk-based capital requirements for
unsettled and failed transactions until
the situation is rectified.
The final rule provides separate
treatments for delivery-versus-payment
(DvP) and payment-versus-payment
(PvP) transactions with a normal
settlement period, and non-DvP/nonPvP transactions with a normal
settlement period. A DvP transaction
refers to a securities or commodities
transaction in which the buyer is
obligated to make payment only if the
seller has made delivery of the
securities or commodities and the seller
is obligated to deliver the securities or
commodities only if the buyer has made
payment. A PvP transaction means a
foreign exchange transaction in which
each counterparty is obligated to make
a final transfer of one or more currencies
only if the other counterparty has made
a final transfer of one or more
currencies. A transaction is considered
to have a normal settlement period if the
contractual settlement period for the
transaction is equal to or less than the
market standard for the instrument
underlying the transaction and equal to
or less than five business days.
Consistent with the proposal, under
the final rule, a banking organization is
required to hold risk-based capital
against a DvP or PvP transaction with a
normal settlement period if the banking
organization’s counterparty has not
made delivery or payment within five
business days after the settlement date.
The banking organization determines its
risk-weighted asset amount for such a
transaction by multiplying the positive
current exposure of the transaction for
the banking organization by the
appropriate risk weight in Table 23. The
positive current exposure from an
unsettled transaction of a banking
organization is the difference between
the transaction value at the agreed
settlement price and the current market
price of the transaction, if the difference
170 Such transactions are treated as derivative
contracts as provided in section 34 or section 35 of
the final rule.
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results in a credit exposure of the
banking organization to the
counterparty.
rule.171 They would have replaced both
the ratings-based approach and an
approach that permits banking
organizations to use supervisorapproved internal systems to replicate
TABLE 23—RISK WEIGHTS FOR UNSETTLED DVP AND PVP TRANS- external ratings processes for certain
unrated exposures in the general riskACTIONS
based capital rules.
In addition, the agencies and the FDIC
Risk weight to be
proposed to update the terminology for
Number of business days
applied to
after contractual
positive current
the securitization framework, include a
settlement date
exposure
definition of securitization exposure
(in percent)
that encompasses a wider range of
From 5 to 15 .....................
100.0 exposures with similar risk
From 16 to 30 ...................
625.0 characteristics, and implement new due
From 31 to 45 ...................
937.5 diligence requirements for securitization
46 or more ........................
1,250.0 exposures.
A banking organization must hold
risk-based capital against any non-DvP/
non-PvP transaction with a normal
settlement period if the banking
organization delivered cash, securities,
commodities, or currencies to its
counterparty but has not received its
corresponding deliverables by the end
of the same business day. The banking
organization must continue to hold riskbased capital against the transaction
until it has received the corresponding
deliverables. From the business day
after the banking organization has made
its delivery until five business days after
the counterparty delivery is due, the
banking organization must calculate the
risk-weighted asset amount for the
transaction by risk weighting the current
fair value of the deliverables owed to
the banking organization, using the risk
weight appropriate for an exposure to
the counterparty in accordance with
section 32. If a banking organization has
not received its deliverables by the fifth
business day after the counterparty
delivery due date, the banking
organization must assign a 1,250 percent
risk weight to the current market value
of the deliverables owed.
H. Risk-Weighted Assets for
Securitization Exposures
In the proposal, the agencies and the
FDIC proposed to significantly revise
the risk-based capital framework for
securitization exposures. These
proposed revisions included removing
references to and reliance on credit
ratings to determine risk weights for
these exposures and using alternative
standards of creditworthiness, as
required by section 939A of the DoddFrank Act. These alternative standards
were designed to produce capital
requirements that generally would be
consistent with those under the BCBS
securitization framework and were
consistent with those incorporated into
the agencies’ and the FDIC’s market risk
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1. Overview of the Securitization
Framework and Definitions
The proposed securitization
framework was designed to address the
credit risk of exposures that involve the
tranching of credit risk of one or more
underlying financial exposures.
Consistent with the proposal, the final
rule defines a securitization exposure as
an on- or off-balance sheet credit
exposure (including credit-enhancing
representations and warranties) that
arises from a traditional or synthetic
securitization (including a
resecuritization), or an exposure that
directly or indirectly references a
securitization exposure. Commenters
expressed concerns that the proposed
scope of the securitization framework
was overly broad and requested that the
definition of securitizations be
narrowed to exposures that tranche the
credit risk associated with a pool of
assets. However, the agencies believe
that limiting the securitization
framework to exposures backed by a
pool of assets would exclude tranched
credit risk exposures that are
appropriately captured under the
securitization framework, such as
certain first loss or other tranched
guarantees provided to a single
underlying exposure.
In the proposal a traditional
securitization was defined, in part, as a
transaction in which credit risk of one
or more underlying exposures has been
transferred to one or more third parties
(other than through the use of credit
derivatives or guarantees), where the
credit risk associated with the
underlying exposures has been
separated into at least two tranches
reflecting different levels of seniority.
The definition included certain other
conditions, such as requiring all or
substantially all of the underlying
exposures to be financial exposures. The
agencies have decided to finalize the
171 77
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FR 53060 (August 30, 2012).
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definition of traditional securitization
largely as proposed, with some revisions
(as discussed below), that reflect certain
comments regarding exclusions under
the framework and other modifications
to the final rule.
Both the designation of exposures as
securitization exposures (or
resecuritization exposures, as described
below) and the calculation of risk-based
capital requirements for securitization
exposures under the final rule are
guided by the economic substance of a
transaction rather than its legal form.
Provided there is tranching of credit
risk, securitization exposures could
include, among other things, ABS and
MBS, loans, lines of credit, liquidity
facilities, financial standby letters of
credit, credit derivatives and guarantees,
loan servicing assets, servicer cash
advance facilities, reserve accounts,
credit-enhancing representations and
warranties, and CEIOs. Securitization
exposures also include assets sold with
retained tranches.
The agencies believe that requiring all
or substantially all of the underlying
exposures of a securitization to be
financial exposures creates an important
boundary between the general credit
risk framework and the securitization
framework. Examples of financial
exposures include loans, commitments,
credit derivatives, guarantees,
receivables, asset-backed securities,
mortgage-backed securities, other debt
securities, or equity securities. Based on
their cash flow characteristics, the
agencies also consider asset classes such
as lease residuals and entertainment
royalties to be financial assets. The
securitization framework is not
designed, however, to apply to tranched
credit exposures to commercial or
industrial companies or nonfinancial
assets or to amounts deducted from
capital under section 22 of the final
rule. Accordingly, a specialized loan to
finance the construction or acquisition
of large-scale projects (for example,
airports or power plants), objects (for
example, ships, aircraft, or satellites), or
commodities (for example, reserves,
inventories, precious metals, oil, or
natural gas) generally would not be a
securitization exposure because the
assets backing the loan typically are
nonfinancial assets (the facility, object,
or commodity being financed).
Consistent with the proposal, under
the final rule, an operating company
does not fall under the definition of a
traditional securitization (even if
substantially all of its assets are
financial exposures). Operating
companies generally refer to companies
that are established to conduct business
with clients with the intention of
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earning a profit in their own right and
generally produce goods or provide
services beyond the business of
investing, reinvesting, holding, or
trading in financial assets. Accordingly,
an equity investment in an operating
company generally would be an equity
exposure. Under the final rule, banking
organizations are operating companies
and do not fall under the definition of
a traditional securitization. However,
investment firms that generally do not
produce goods or provide services
beyond the business of investing,
reinvesting, holding, or trading in
financial assets, would not be operating
companies under the final rule and
would not qualify for this general
exclusion from the definition of
traditional securitization.
Under the proposed rule, paragraph
(10) of the definition of traditional
securitization specifically excluded
exposures to investment funds (as
defined in the proposal) and collective
investment and pension funds (as
defined in relevant regulations and set
forth in the proposed definition of
‘‘traditional securitization’’). These
specific exemptions served to narrow
the potential scope of the securitization
framework. Investment funds, collective
investment funds, pension funds
regulated under ERISA and their foreign
equivalents, and transactions registered
with the SEC under the Investment
Company Act of 1940 and their foreign
equivalents would be exempted from
the definition because these entities and
transactions are regulated and subject to
strict leverage requirements. The
proposal defined an investment fund as
a company (1) where all or substantially
all of the assets of the fund are financial
assets; and (2) that has no material
liabilities. In addition, the agencies
explained in the proposal that the
capital requirements for an extension of
credit to, or an equity holding in, these
transactions are more appropriately
calculated under the rules for corporate
and equity exposures, and that the
securitization framework was not
intended to apply to such transactions.
Commenters generally agreed with the
proposed exemptions from the
definition of traditional securitization
and requested that the agencies and the
FDIC provide exemptions for exposures
to a broader set of investment firms,
such as pension funds operated by state
and local governments. In view of the
comments regarding pension funds, the
final rule provides an additional
exclusion from the definition of
traditional securitization for a
‘‘governmental plan’’ (as defined in 29
U.S.C. 1002(32)) that complies with the
tax deferral qualification requirements
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provided in the Internal Revenue Code.
The agencies believe that an exemption
for such government plans is
appropriate because they are subject to
substantial regulation. Commenters also
requested that the agencies and the
FDIC provide exclusions for certain
products provided to investment firms,
such as extensions of short-term credit
that support day-to-day investmentrelated activities. The agencies believe
that exposures that meet the definition
of traditional securitization, regardless
of product type or maturity, would fall
under the securitization framework.
Accordingly, the agencies have not
provided for any such exemptions
under the final rule.172
To address the treatment of
investment firms that are not
specifically excluded from the
securitization framework, the proposed
rule provided discretion to the primary
Federal supervisor of a banking
organization to exclude from the
definition of a traditional securitization
those transactions in which the
underlying exposures are owned by an
investment firm that exercises
substantially unfettered control over the
size and composition of its assets,
liabilities, and off-balance sheet
exposures. While the commenters
supported the agencies’ and the FDIC’s
recognition that certain investment
firms may warrant an exemption from
the securitization framework, some
expressed concern that the process for
making such a determination may
present significant implementation
burden.
To maintain sufficient flexibility to
provide an exclusion for certain
investment firms from the securitization
framework, the agencies have retained
this discretionary provision in the final
rule without change. In determining
whether to exclude an investment firm
from the securitization framework, the
agencies will consider a number of
factors, including the assessment of the
transaction’s leverage, risk profile, and
economic substance. This supervisory
exclusion gives the primary Federal
supervisor discretion to distinguish
structured finance transactions, to
which the securitization framework is
designed to apply, from those of flexible
investment firms, such as certain hedge
funds and private equity funds. Only
investment firms that can easily change
the size and composition of their capital
structure, as well as the size and
composition of their assets and off172 The final rule also clarifies that the portion of
a synthetic exposure to the capital of a financial
institution that is deducted from capital is not a
traditional securitization.
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balance sheet exposures, are eligible for
the exclusion from the definition of
traditional securitization under this
provision. The agencies do not consider
managed collateralized debt obligation
vehicles, structured investment
vehicles, and similar structures, which
allow considerable management
discretion regarding asset composition
but are subject to substantial restrictions
regarding capital structure, to have
substantially unfettered control. Thus,
such transactions meet the definition of
traditional securitization under the final
rule.
The line between securitization
exposures and non-securitization
exposures may be difficult to identify in
some circumstances. In addition to the
supervisory exclusion from the
definition of traditional securitization
described above, the primary Federal
supervisor may expand the scope of the
securitization framework to include
other transactions if doing so is justified
by the economics of the transaction.
Similar to the analysis for excluding an
investment firm from treatment as a
traditional securitization, the agencies
will consider the economic substance,
leverage, and risk profile of a
transaction to ensure that an appropriate
risk-based capital treatment is applied.
The agencies will consider a number of
factors when assessing the economic
substance of a transaction including, for
example, the amount of equity in the
structure, overall leverage (whether onor off-balance sheet), whether
redemption rights attach to the equity
investor, and the ability of the junior
tranches to absorb losses without
interrupting contractual payments to
more senior tranches.
Under the proposal, a synthetic
securitization was defined as a
transaction in which: (1) All or a portion
of the credit risk of one or more
underlying exposures is transferred to
one or more third parties through the
use of one or more credit derivatives or
guarantees (other than a guarantee that
transfers only the credit risk of an
individual retail exposure); (2) the
credit risk associated with the
underlying exposures has been
separated into at least two tranches
reflecting different levels of seniority;
(3) performance of the securitization
exposures depends upon the
performance of the underlying
exposures; and (4) all or substantially all
of the underlying exposures are
financial exposures (such as loans,
commitments, credit derivatives,
guarantees, receivables, asset-backed
securities, mortgage-backed securities,
other debt securities, or equity
securities). The agencies have decided
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to finalize the definition of synthetic
securitization largely as proposed, but
have also clarified in the final rule that
transactions in which a portion of credit
risk has been retained, not just
transferred, through the use of credit
derivatives is subject to the
securitization framework.
In response to the proposal,
commenters requested that the agencies
and the FDIC provide an exemption for
guarantees that tranche credit risk under
certain mortgage partnership finance
programs, such as certain programs
provided by the FHLBs, whereby
participating member banking
organizations provide credit
enhancement to a pool of residential
mortgage loans that have been delivered
to the FHLB. The agencies believe that
these exposures that tranche credit risk
meet the definition of a synthetic
securitization and that the risk of such
exposures would be appropriately
captured under the securitization
framework. In contrast, mortgage-backed
pass-through securities (for example,
those guaranteed by FHLMC or FNMA)
that feature various maturities but do
not involve tranching of credit risk do
not meet the definition of a
securitization exposure. Only those
MBS that involve tranching of credit
risk are considered to be securitization
exposures.
Consistent with the 2009
Enhancements, the proposed rule
defined a resecuritization exposure as
an on- or off-balance sheet exposure to
a resecuritization; or an exposure that
directly or indirectly references a
resecuritization exposure. A
resecuritization would have meant a
securitization in which one or more of
the underlying exposures is a
securitization exposure. An exposure to
an asset-backed commercial paper
(ABCP) program would not have been a
resecuritization exposure if either: (1)
The program-wide credit enhancement
does not meet the definition of a
resecuritization exposure; or (2) the
entity sponsoring the program fully
supports the commercial paper through
the provision of liquidity so that the
commercial paper holders effectively
are exposed to the default risk of the
sponsor instead of the underlying
exposures.
Commenters asked the agencies and
the FDIC to narrow the definition of
resecuritization by exempting
resecuritizations in which a minimal
amount of underlying assets are
securitization exposures. According to
commenters, the proposed definition
would have a detrimental effect on
certain collateralized loan obligation
exposures, which typically include a
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small amount of securitization
exposures as part of the underlying pool
of assets in a securitization. Specifically,
the commenters requested that
resecuritizations be defined as a
securitization in which five percent or
more of the underlying exposures are
securitizations. Commenters also asked
the agencies and the FDIC to consider
employing a pro rata treatment by only
applying a higher capital surcharge to
the portion of a securitization exposure
that is backed by underlying
securitization exposures. The agencies
believe that the introduction of
securitization exposures into a pool of
securitized exposures significantly
increases the complexity and correlation
risk of the exposures backing the
securities issued in the transaction, and
that the resecuritization framework is
appropriate for applying risk-based
capital requirements to exposures to
pools that contain securitization
exposures.
Commenters sought clarification as to
whether the proposed definition of
resecuritization would include a single
exposure that has been retranched, such
as a resecuritization of a real estate
mortgage investment conduit (ReREMIC). The agencies believe that the
increased capital surcharge, or p factor,
for resecuritizations was meant to
address the increased correlation risk
and complexity resulting from
retranching of multiple underlying
exposures and was not intended to
apply to the retranching of a single
underlying exposure. As a result, the
definition of resecuritization in the final
rule has been refined to clarify that
resecuritizations do not include
exposures comprised of a single asset
that has been retranched. The agencies
note that for purposes of the final rule,
a resecuritization does not include passthrough securities that have been pooled
together and effectively re-issued as
tranched securities. This is because the
pass-through securities do not tranche
credit protection and, as a result, are not
considered securitization exposures
under the final rule.
Under the final rule, if a transaction
involves a traditional multi-seller ABCP
conduit, a banking organization must
determine whether the transaction
should be considered a resecuritization
exposure. For example, assume that an
ABCP conduit acquires securitization
exposures where the underlying assets
consist of wholesale loans and no
securitization exposures. As is typically
the case in multi-seller ABCP conduits,
each seller provides first-loss protection
by over-collateralizing the conduit to
which it sells loans. To ensure that the
commercial paper issued by each
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conduit is highly-rated, a banking
organization sponsor provides either a
pool-specific liquidity facility or a
program-wide credit enhancement such
as a guarantee to cover a portion of the
losses above the seller-provided
protection.
The pool-specific liquidity facility
generally is not a resecuritization
exposure under the final rule because
the pool-specific liquidity facility
represents a tranche of a single asset
pool (that is, the applicable pool of
wholesale exposures), which contains
no securitization exposures. However, a
sponsor’s program-wide credit
enhancement that does not cover all
losses above the seller-provided credit
enhancement across the various pools
generally constitutes tranching of risk of
a pool of multiple assets containing at
least one securitization exposure, and,
therefore, is a resecuritization exposure.
In addition, if the conduit in this
example funds itself entirely with a
single class of commercial paper, then
the commercial paper generally is not a
resecuritization exposure if, as noted
above, either (1) the program-wide
credit enhancement does not meet the
definition of a resecuritization exposure
or (2) the commercial paper is fully
supported by the sponsoring banking
organization. When the sponsoring
banking organization fully supports the
commercial paper, the commercial
paper holders effectively are exposed to
default risk of the sponsor instead of the
underlying exposures, and the external
rating of the commercial paper is
expected to be based primarily on the
credit quality of the banking
organization sponsor, thus ensuring that
the commercial paper does not
represent a tranched risk position.
2. Operational Requirements
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a. Due Diligence Requirements
During the recent financial crisis, it
became apparent that many banking
organizations relied exclusively on
ratings issued by Nationally Recognized
Statistical Rating Organizations
(NRSROs) and did not perform internal
credit analysis of their securitization
exposures. Consistent with the Basel
capital framework and the agencies’
general expectations for investment
analysis, the proposal required banking
organizations to satisfy specific due
diligence requirements for securitization
exposures. Specifically, under the
proposal a banking organization would
be required to demonstrate, to the
satisfaction of its primary Federal
supervisor, a comprehensive
understanding of the features of a
securitization exposure that would
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materially affect its performance. The
banking organization’s analysis would
have to be commensurate with the
complexity of the exposure and the
materiality of the exposure in relation to
capital of the banking organization. On
an ongoing basis (no less frequently
than quarterly), the banking
organization must evaluate, review, and
update as appropriate the analysis
required under section 41(c)(1) of the
proposed rule for each securitization
exposure. The analysis of the risk
characteristics of the exposure prior to
acquisition, and periodically thereafter,
would have to consider:
(1) Structural features of the
securitization that materially impact the
performance of the exposure, for
example, the contractual cash-flow
waterfall, waterfall-related triggers,
credit enhancements, liquidity
enhancements, market value triggers,
the performance of organizations that
service the position, and deal-specific
definitions of default;
(2) Relevant information regarding the
performance of the underlying credit
exposure(s), for example, the percentage
of loans 30, 60, and 90 days past due;
default rates; prepayment rates; loans in
foreclosure; property types; occupancy;
average credit score or other measures of
creditworthiness; average LTV ratio; and
industry and geographic diversification
data on the underlying exposure(s);
(3) Relevant market data of the
securitization, for example, bid-ask
spread, most recent sales price and
historical price volatility, trading
volume, implied market rating, and size,
depth and concentration level of the
market for the securitization; and
(4) For resecuritization exposures,
performance information on the
underlying securitization exposures, for
example, the issuer name and credit
quality, and the characteristics and
performance of the exposures
underlying the securitization exposures.
Commenters expressed concern that
many banking organizations would be
unable to perform the due diligence
necessary to meet the requirements and,
as a result, would no longer purchase
privately-issued securitization
exposures and would increase their
holdings of GSE-guaranteed securities,
thereby increasing the size of the GSEs.
Commenters also expressed concerns
regarding banking organizations’ ability
to obtain relevant market data for
certain exposures, such as foreign
exposures and exposures that are traded
in markets that are typically illiquid, as
well as their ability to obtain market
data during periods of general market
illiquidity. Commenters also stated
concerns that uneven application of the
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requirements by supervisors may result
in disparate treatment for the same
exposure held at different banking
organizations due to perceived
management deficiencies. For these
reasons, many commenters requested
that the agencies and the FDIC consider
removing the market data requirement
from the due diligence requirements. In
addition, some commenters suggested
that the due diligence requirements be
waived provided that all of the
underlying loans meet certain
underwriting standards.
The agencies note that the proposed
due diligence requirements are
generally consistent with the goal of the
agencies’ investment permissibility
requirements, which provide that
banking organizations must be able to
determine the risk of loss is low, even
under adverse economic conditions.
The agencies acknowledge potential
restrictions on data availability and
believe that the standards provide
sufficient flexibility so that the due
diligence requirements, such as relevant
market data requirements, would be
implemented as applicable. In addition,
the agencies note that, where
appropriate, pool-level data could be
used to meet certain of the due diligence
requirements. As a result, the agencies
are adopting the due diligence
requirements as proposed.
Under the proposal, if a banking
organization is not able to meet these
due diligence requirements and
demonstrate a comprehensive
understanding of a securitization
exposure to the satisfaction of its
primary Federal supervisor, the banking
organization would be required to
assign a risk weight of 1,250 percent to
the exposure. Commenters requested
that the agencies and the FDIC adopt a
more flexible approach to due diligence
requirements rather than requiring a
banking organization to assign a risk
weight of 1,250 percent for violation of
those requirements. For example, some
commenters recommended that the
agencies and the FDIC assign
progressively increasing risk weights
based on the severity and duration of
infringements of due diligence
requirements, to allow the agencies and
the FDIC to differentiate between minor
gaps in due diligence requirements and
more serious violations.
The agencies believe that the
requirement to assign a 1,250 percent
risk weight, rather than applying a
lower risk weight, to exposures for
violation of these requirements is
appropriate given that such information
is required to monitor appropriately the
risk of the underlying assets. The
agencies recognize the importance of
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consistent and uniform application of
the standards across banking
organizations and will endeavor to
ensure that supervisors consistently
review banking organizations’ due
diligence on securitization exposures.
The agencies believe that these efforts
will mitigate concerns that the 1,250
percent risk weight will be applied
inappropriately to banking
organizations’ failure to meet the due
diligence requirements. At the same
time, the agencies believe that the
requirement that a banking
organization’s analysis be
commensurate with the complexity and
materiality of the securitization
exposure provides the banking
organization with sufficient flexibility to
mitigate the potential for undue burden.
As a result, the agencies are adopting
the risk weight requirements related to
due diligence requirements as proposed.
b. Operational Requirements for
Traditional Securitizations
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The proposal outlined certain
operational requirements for traditional
securitizations that had to be met in
order to apply the securitization
framework. The agencies are adopting
these operational requirements as
proposed.
In a traditional securitization, an
originating banking organization
typically transfers a portion of the credit
risk of exposures to third parties by
selling them to a securitization special
purpose entity (SPE).173 Consistent with
the proposal, the final rule defines a
banking organization to be an
originating banking organization with
respect to a securitization if it (1)
directly or indirectly originated or
securitized the underlying exposures
included in the securitization; or (2)
serves as an ABCP program sponsor to
the securitization.
Under the final rule, consistent with
the proposal, a banking organization
that transfers exposures it has originated
or purchased to a securitization SPE or
other third party in connection with a
traditional securitization can exclude
the underlying exposures from the
calculation of risk-weighted assets only
if each of the following conditions are
met: (1) The exposures are not reported
on the banking organization’s
consolidated balance sheet under
173 The final rule defines a securitization SPE as
a corporation, trust, or other entity organized for the
specific purpose of holding underlying exposures of
a securitization, the activities of which are limited
to those appropriate to accomplish this purpose,
and the structure of which is intended to isolate the
underlying exposures held by the entity from the
credit risk of the seller of the underlying exposures
to the entity.
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GAAP; (2) the banking organization has
transferred to one or more third parties
credit risk associated with the
underlying exposures; and (3) any
clean-up calls relating to the
securitization are eligible clean-up calls
(as discussed below).174
An originating banking organization
that meets these conditions must hold
risk-based capital against any credit risk
it retains or acquires in connection with
the securitization. An originating
banking organization that fails to meet
these conditions is required to hold riskbased capital against the transferred
exposures as if they had not been
securitized and must deduct from
common equity tier 1 capital any aftertax gain-on-sale resulting from the
transaction.
In addition, if a securitization (1)
includes one or more underlying
exposures in which the borrower is
permitted to vary the drawn amount
within an agreed limit under a line of
credit, and (2) contains an early
amortization provision, the originating
banking organization is required to hold
risk-based capital against the transferred
exposures as if they had not been
securitized and deduct from common
equity tier 1 capital any after-tax gainon-sale resulting from the
transaction.175 The agencies believe that
this treatment is appropriate given the
174 Commenters asked the agencies and the FDIC
to consider the interaction between the proposed
non-consolidation condition and the agencies’ and
the FDIC’s proposed rules implementing section
941 of the Dodd-Frank Act regarding risk retention,
given concerns that satisfaction of certain of the
proposed risk retention requirements would affect
the accounting treatment for certain transactions.
The agencies acknowledge these concerns and will
take into consideration any effects on the
securitization framework as they continue to
develop the risk retention rules.
175 Many securitizations of revolving credit
facilities (for example, credit card receivables)
contain provisions that require the securitization to
be wound down and investors to be repaid if the
excess spread falls below a certain threshold. This
decrease in excess spread may, in some cases, be
caused by deterioration in the credit quality of the
underlying exposures. An early amortization event
can increase a banking organization’s capital needs
if new draws on the revolving credit facilities need
to be financed by the banking organization using
on-balance sheet sources of funding. The payment
allocations used to distribute principal and finance
charge collections during the amortization phase of
these transactions also can expose a banking
organization to a greater risk of loss than in other
securitization transactions. The final rule defines an
early amortization provision as a provision in a
securitization’s governing documentation that,
when triggered, causes investors in the
securitization exposures to be repaid before the
original stated maturity of the securitization
exposure, unless the provision (1) is solely triggered
by events not related to the performance of the
underlying exposures or the originating banking
organization (such as material changes in tax laws
or regulations), or (2) leaves investors fully exposed
to future draws by borrowers on the underlying
exposures even after the provision is triggered.
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62115
lack of risk transference in
securitizations of revolving underlying
exposures with early amortization
provisions.
c. Operational Requirements for
Synthetic Securitizations
In general, the proposed operational
requirements for synthetic
securitizations were similar to those
proposed for traditional securitizations.
The operational requirements for
synthetic securitizations, however, were
more detailed to ensure that the
originating banking organization has
truly transferred credit risk of the
underlying exposures to one or more
third parties. Under the proposal, an
originating banking organization would
have been able to recognize for riskbased capital purposes the use of a
credit risk mitigant to hedge underlying
exposures only if each of the conditions
in the proposed definition of ‘‘synthetic
securitization’’ was satisfied. The
agencies are adopting the operational
requirements largely as proposed.
However, to ensure that synthetic
securitizations created through tranched
guarantees and credit derivatives are
properly included in the framework, in
the final rule the agencies have
amended the operational requirements
to recognize guarantees that meet all of
the criteria set forth in the definition of
eligible guarantee except the criterion
under paragraph (3) of the definition.
Additionally, the operational criteria
recognize a credit derivative provided
that the credit derivative meets all of the
criteria set forth in the definition of
eligible credit derivative except for
paragraph 3 of the definition of eligible
guarantee. As a result, a guarantee or
credit derivative that provides a
tranched guarantee would not be
excluded by the operational
requirements for synthetic
securitizations.
Failure to meet these operational
requirements for a synthetic
securitization prevents a banking
organization that has purchased
tranched credit protection referencing
one or more of its exposures from using
the securitization framework with
respect to the reference exposures and
requires the banking organization to
hold risk-based capital against the
underlying exposures as if they had not
been synthetically securitized. A
banking organization that holds a
synthetic securitization as a result of
purchasing credit protection may use
the securitization framework to
determine the risk-based capital
requirement for its exposure.
Alternatively, it may instead choose to
disregard the credit protection and use
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the general credit risk framework. A
banking organization that provides
tranched credit protection in the form of
a synthetic securitization or credit
protection to a synthetic securitization
must use the securitization framework
to compute risk-based capital
requirements for its exposures to the
synthetic securitization even if the
originating banking organization fails to
meet one or more of the operational
requirements for a synthetic
securitization.
d. Clean-Up Calls
Under the proposal, to satisfy the
operational requirements for
securitizations and enable an originating
banking organization to exclude the
underlying exposures from the
calculation of its risk-based capital
requirements, any clean-up call
associated with a securitization would
need to be an eligible clean-up call. The
proposed rule defined a clean-up call as
a contractual provision that permits an
originating banking organization or
servicer to call securitization exposures
before their stated maturity or call date.
In the case of a traditional
securitization, a clean-up call generally
is accomplished by repurchasing the
remaining securitization exposures once
the amount of underlying exposures or
outstanding securitization exposures
falls below a specified level. In the case
of a synthetic securitization, the cleanup call may take the form of a clause
that extinguishes the credit protection
once the amount of underlying
exposures has fallen below a specified
level.
The final rule retains the proposed
treatment for clean-up calls, and defines
an eligible clean-up call as a clean-up
call that (1) is exercisable solely at the
discretion of the originating banking
organization or servicer; (2) is not
structured to avoid allocating losses to
securitization exposures held by
investors or otherwise structured to
provide credit enhancement to the
securitization (for example, to purchase
non-performing underlying exposures);
and (3) for a traditional securitization, is
only exercisable when 10 percent or less
of the principal amount of the
underlying exposures or securitization
exposures (determined as of the
inception of the securitization) is
outstanding; or, for a synthetic
securitization, is only exercisable when
10 percent or less of the principal
amount of the reference portfolio of
underlying exposures (determined as of
the inception of the securitization) is
outstanding. Where a securitization SPE
is structured as a master trust, a cleanup call with respect to a particular
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series or tranche issued by the master
trust meets criteria (3) of the definition
of ‘‘eligible clean-up call’’ as long as the
outstanding principal amount in that
series or tranche was 10 percent or less
of its original amount at the inception
of the series.
3. Risk-Weighted Asset Amounts for
Securitization Exposures
The proposed framework for assigning
risk-based capital requirements to
securitization exposures required
banking organizations generally to
calculate a risk-weighted asset amount
for a securitization exposure by
applying either (i) the simplified
supervisory formula approach (SSFA),
described in section VIII.H of the
preamble, or (ii) if the banking
organization is not subject to the market
risk rule, a gross-up approach similar to
an approach provided under the general
risk-based capital rules. A banking
organization would be required to apply
either the SSFA or the gross-up
approach consistently across all of its
securitization exposures. However, a
banking organization could choose to
assign a 1,250 percent risk weight to any
securitization exposure.
Commenters expressed concerns
regarding the potential differences in
risk weights for similar exposures when
using the gross-up approach compared
to the SSFA, and the potential for
capital arbitrage depending on the
outcome of capital treatment under the
framework. The agencies acknowledge
these concerns and, to reduce arbitrage
opportunities, have required that a
banking organization apply either the
gross-up approach or the SSFA
consistently across all of its
securitization exposures. Commenters
also asked the agencies and the FDIC to
clarify how often and under what
circumstances a banking organization is
allowed to switch between the SSFA
and the gross-up approach. While the
agencies are not placing restrictions on
the ability of banking organizations to
switch from the SSFA to the gross-up
approach, the agencies do not anticipate
there should be a need for frequent
changes in methodology by a banking
organization absent significant change
in the nature of the banking
organization’s securitization activities,
and expect banking organizations to be
able to provide a rationale for changing
methodologies to their primary Federal
supervisors if requested.
Citing potential disadvantages of the
proposed securitization framework as
compared to standards to be applied to
international competitors that rely on
the use of credit ratings, some
commenters requested that banking
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organizations be able to continue to
implement a ratings-based approach to
allow the agencies and the FDIC more
time to calibrate the SSFA in
accordance with international standards
that rely on ratings. The agencies again
observe that in accordance with section
939A of the Dodd-Frank Act, they are
required to remove any references to, or
reliance on, ratings in regulations.
Accordingly, the final rule does not
include any references to, or reliance
on, credit ratings. The agencies have
determined that the SSFA is an
appropriate substitute standard to credit
ratings that can be used to measure riskbased capital requirements and may be
implemented uniformly across
institutions. Under the proposed
securitization framework, banking
organizations would have been required
or could choose to assign a risk weight
of 1,250 percent to certain securitization
exposures. Commenters stated that the
1,250 percent risk weight required
under certain circumstances in the
securitization framework would
penalize banking organizations that
hold capital above the total risk-based
capital minimum and could require a
banking organization to hold more
capital against the exposure than the
actual exposure amount at risk. As a
result, commenters requested that the
amount of risk-based capital required to
be held against a banking organization’s
exposure be capped at the exposure
amount. The agencies have decided to
retain the proposed 1,250 percent risk
weight in the final rule, consistent with
their overall goals of simplicity and
comparability, to provide for
comparability in risk-weighted asset
amounts for the same exposure across
institutions.
Consistent with the proposal, the final
rule provides for alternative treatment of
securitization exposures to ABCP
programs and certain gains-on-sale and
CEIO exposures. Specifically, similar to
the general risk-based capital rules, the
final rule includes a minimum 100
percent risk weight for interest-only
mortgage-backed securities and
exceptions to the securitization
framework for certain small-business
loans and certain derivatives as
described below. A banking
organization may use the securitization
credit risk mitigation rules to adjust the
capital requirement under the
securitization framework for an
exposure to reflect certain collateral,
credit derivatives, and guarantees, as
described in more detail below.
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a. Exposure Amount of a Securitization
Exposure
Under the final rule, the exposure
amount of an on-balance sheet
securitization exposure that is not a
repo-style transaction, eligible margin
loan, OTC derivative contract or
derivative that is a cleared transaction is
generally the banking organization’s
carrying value of the exposure. The final
rule modifies the proposed treatment for
determining exposure amounts under
the securitization framework to reflect
the ability of a banking organization not
subject to the advanced approaches rule
to make an AOCI opt-out election. As a
result, the exposure amount of an onbalance sheet securitization exposure
that is an available-for-sale debt security
or an available-for-sale debt security
transferred to held-to-maturity held by a
banking organization that has made an
AOCI opt-out election is the banking
organization’s carrying value (including
net accrued but unpaid interest and
fees), less any net unrealized gains on
the exposure and plus any net
unrealized losses on the exposure.
The exposure amount of an offbalance sheet securitization exposure
that is not an eligible ABCP liquidity
facility, a repo-style transaction, eligible
margin loan, an OTC derivative contract
(other than a credit derivative), or a
derivative that is a cleared transaction
(other than a credit derivative) is the
notional amount of the exposure. The
treatment for OTC credit derivatives is
described in more detail below.
For purposes of calculating the
exposure amount of an off-balance sheet
exposure to an ABCP securitization
exposure, such as a liquidity facility,
consistent with the proposed rule, the
notional amount may be reduced to the
maximum potential amount that the
banking organization could be required
to fund given the ABCP program’s
current underlying assets (calculated
without regard to the current credit
quality of those assets). Thus, if $100 is
the maximum amount that could be
drawn given the current volume and
current credit quality of the program’s
assets, but the maximum potential draw
against these same assets could increase
to as much as $200 under some
scenarios if their credit quality were to
improve, then the exposure amount is
$200. An ABCP program is defined as a
program established primarily for the
purpose of issuing commercial paper
that is investment grade and backed by
underlying exposures held in a
securitization SPE. An eligible ABCP
liquidity facility is defined as a liquidity
facility supporting ABCP, in form or in
substance, which is subject to an asset
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quality test at the time of draw that
precludes funding against assets that are
90 days or more past due or in default.
Notwithstanding these eligibility
requirements, a liquidity facility is an
eligible ABCP liquidity facility if the
assets or exposures funded under the
liquidity facility that do not meet the
eligibility requirements are guaranteed
by a sovereign that qualifies for a 20
percent risk weight or lower.
Commenters, citing accounting
changes that require certain ABCP
securitization exposures to be
consolidated on banking organizations
balance sheets, asked the agencies and
the FDIC to consider capping the
amount of an off-balance sheet
securitization exposure to the maximum
potential amount that the banking
organization could be required to fund
given the securitization SPE’s current
underlying assets. These commenters
stated that the downward adjustment of
the notional amount of a banking
organization’s off-balance sheet
securitization exposure to the amount of
the available asset pool generally should
be permitted regardless of whether the
exposure to a customer SPE is made
directly through a credit commitment by
the banking organization to the SPE or
indirectly through a funding
commitment that the banking
organization makes to an ABCP conduit.
The agencies believe that the
requirement to hold risk-based capital
against the full amount that may be
drawn more accurately reflects the risks
of potential draws under these
exposures and have decided not to
provide a separate provision for offbalance sheet exposures to customersponsored SPEs that are not ABCP
conduits.
Under the final rule, consistent with
the proposal, the exposure amount of an
eligible ABCP liquidity facility that is
subject to the SSFA equals the notional
amount of the exposure multiplied by a
100 percent CCF. The exposure amount
of an eligible ABCP liquidity facility
that is not subject to the SSFA is the
notional amount of the exposure
multiplied by a 50 percent CCF. The
exposure amount of a securitization
exposure that is a repo-style transaction,
eligible margin loan, an OTC derivative
contract (other than a purchased credit
derivative), or derivative that is a
cleared transaction (other than a
purchased credit derivative) is the
exposure amount of the transaction as
calculated under section 34 or section
37 of the final rule, as applicable.
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62117
b. Gains-On-Sale and Credit-Enhancing
Interest-Only Strips
Consistent with the proposal, under
the final rule a banking organization
must deduct from common equity tier 1
capital any after-tax gain-on-sale
resulting from a securitization and must
apply a 1,250 percent risk weight to the
portion of a CEIO that does not
constitute an after-tax gain-on-sale. The
agencies believe this treatment is
appropriate given historical supervisory
concerns with the subjectivity involved
in valuations of gains-on-sale and
CEIOs. Furthermore, although the
treatments for gains-on-sale and CEIOs
can increase an originating banking
organization’s risk-based capital
requirement following a securitization,
the agencies believe that such anomalies
are rare where a securitization transfers
significant credit risk from the
originating banking organization to third
parties.
c. Exceptions Under the Securitization
Framework
Commenters stated concerns that the
proposal would inhibit demand for
private label securitization by making it
more difficult for banking organizations,
especially community banking
organizations, to purchase private label
mortgage-backed securities. Instead of
implementing the SSFA and the grossup approach, commenters suggested
allowing banking organizations to assign
a 20 percent risk weight to
securitization exposures that are backed
by mortgage exposures that would be
‘‘qualified mortgages’’ under the Truth
in Lending Act and implementing
regulations issued by the CFPB.176 The
agencies believe that the proposed
securitization approaches would be
more appropriate in capturing the risks
provided by structured transactions,
including those backed by QM. The
final rule does not provide an exclusion
for such exposures.
Under the final rule, consistent with
the proposal, there are several
exceptions to the general provisions in
the securitization framework that
parallel the general risk-based capital
rules. First, a banking organization is
required to assign a risk weight of at
least 100 percent to an interest-only
MBS. The agencies believe that a
minimum risk weight of 100 percent is
prudent in light of the uncertainty
implied by the substantial price
volatility of these securities. Second, as
required by federal statute, a special set
of rules continues to apply to
securitizations of small-business loans
176 78
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and leases on personal property
transferred with retained contractual
exposure by well-capitalized depository
institutions.177 Finally, if a
securitization exposure is an OTC
derivative contract or derivative
contract that is a cleared transaction
(other than a credit derivative) that has
a first priority claim on the cash flows
from the underlying exposures
(notwithstanding amounts due under
interest rate or currency derivative
contracts, fees due, or other similar
payments), a banking organization may
choose to set the risk-weighted asset
amount of the exposure equal to the
amount of the exposure.
d. Overlapping Exposures
Consistent with the proposal, the final
rule includes provisions to limit the
double counting of risks in situations
involving overlapping securitization
exposures. If a banking organization has
multiple securitization exposures that
provide duplicative coverage to the
underlying exposures of a securitization
(such as when a banking organization
provides a program-wide credit
enhancement and multiple pool-specific
liquidity facilities to an ABCP program),
the banking organization is not required
to hold duplicative risk-based capital
against the overlapping position.
Instead, the banking organization must
apply to the overlapping position the
applicable risk-based capital treatment
under the securitization framework that
results in the highest risk-based capital
requirement.
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e. Servicer Cash Advances
A traditional securitization typically
employs a servicing banking
organization that, on a day-to-day basis,
collects principal, interest, and other
payments from the underlying
exposures of the securitization and
forwards such payments to the
securitization SPE or to investors in the
securitization. Servicing banking
organizations often provide a facility to
the securitization under which the
servicing banking organization may
advance cash to ensure an
uninterrupted flow of payments to
investors in the securitization, including
advances made to cover foreclosure
costs or other expenses to facilitate the
177 See
12 U.S.C. 1835. This provision places a
cap on the risk-based capital requirement
applicable to a well-capitalized depository
institution that transfers small-business loans with
recourse. The final rule does not expressly provide
that the agencies may permit adequately-capitalized
banking organizations to use the small business
recourse rule on a case-by-case basis because the
agencies may make such a determination under the
general reservation of authority in section 1 of the
final rule.
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timely collection of the underlying
exposures. These servicer cash advance
facilities are securitization exposures.
Consistent with the proposal, under
the final rule a banking organization
must apply the SSFA or the gross-up
approach, as described below, or a 1,250
percent risk weight to a servicer cash
advance facility. The treatment of the
undrawn portion of the facility depends
on whether the facility is an eligible
servicer cash advance facility. An
eligible servicer cash advance facility is
a servicer cash advance facility in
which: (1) The servicer is entitled to full
reimbursement of advances, except that
a servicer may be obligated to make
non-reimbursable advances for a
particular underlying exposure if any
such advance is contractually limited to
an insignificant amount of the
outstanding principal balance of that
exposure; (2) the servicer’s right to
reimbursement is senior in right of
payment to all other claims on the cash
flows from the underlying exposures of
the securitization; and (3) the servicer
has no legal obligation to, and does not
make, advances to the securitization if
the servicer concludes the advances are
unlikely to be repaid.
Under the proposal, a banking
organization that is a servicer under an
eligible servicer cash advance facility is
not required to hold risk-based capital
against potential future cash advanced
payments that it may be required to
provide under the contract governing
the facility. A banking organization that
provides a non-eligible servicer cash
advance facility would determine its
risk-based capital requirement for the
notional amount of the undrawn portion
of the facility in the same manner as the
banking organization would determine
its risk-based capital requirement for
other off-balance sheet securitization
exposures. The agencies are clarifying
the terminology in the final rule to
specify that a banking organization that
is a servicer under a non-eligible
servicer cash advance facility must hold
risk-based capital against the amount of
all potential future cash advance
payments that it may be contractually
required to provide during the
subsequent 12-month period under the
contract governing the facility.
f. Implicit Support
Consistent with the proposed rule, the
final rule requires a banking
organization that provides support to a
securitization in excess of its
predetermined contractual obligation
(implicit support) to include in riskweighted assets all of the underlying
exposures associated with the
securitization as if the exposures had
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not been securitized, and deduct from
common equity tier 1 capital any aftertax gain-on-sale resulting from the
securitization.178 In addition, the
banking organization must disclose
publicly (i) that it has provided implicit
support to the securitization, and (ii) the
risk-based capital impact to the banking
organization of providing such implicit
support. The agencies note that under
the reservations of authority set forth in
the final rule, the banking organization’s
primary Federal supervisor also could
require the banking organization to hold
risk-based capital against all the
underlying exposures associated with
some or all the banking organization’s
other securitizations as if the underlying
exposures had not been securitized, and
to deduct from common equity tier 1
capital any after-tax gain-on-sale
resulting from such securitizations.
4. Simplified Supervisory Formula
Approach
The proposed rule incorporated the
SSFA, a simplified version of the
supervisory formula approach (SFA) in
the advanced approaches rule, to assign
risk weights to securitization exposures.
Many of the commenters focused on the
burden of implementing the SSFA given
the complexity of the approach in
relation to the proposed treatment of
mortgages exposures. Commenters also
stated concerns that implementation of
the SSFA would generally restrict credit
growth and create competitive equity
concerns with other jurisdictions
implementing ratings-based approaches.
The agencies acknowledge that there
may be differences in capital
requirements under the SSFA and the
ratings-based approach in the Basel
capital framework. As explained
previously, section 939A of the DoddFrank Act requires the agencies to use
alternative standards of
creditworthiness and prohibits the
agencies from including references to, or
reliance upon, credit ratings in their
regulations. Any alternative standard
developed by the agencies may not
generate the same result as a ratingsbased capital framework under every
circumstance. However, the agencies
have designed the SSFA to result in
generally comparable capital
requirements to those that would be
required under the Basel ratings-based
approach without undue complexity.
The agencies will monitor
implementation of the SSFA and, based
178 The final rule is consistent with longstanding
guidance on the treatment of implicit support,
entitled, ‘‘Interagency Guidance on Implicit
Recourse in Asset Securitizations,’’ (May 23, 2002).
See OCC Bulletin 2002–20 (national banks) (OCC);
and SR letter 02–15 (Board).
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on supervisory experience, consider
what modifications, if any, may be
necessary to improve the SSFA in the
future.
The agencies have adopted the
proposed SSFA largely as proposed,
with a revision to the delinquency
parameter (parameter W) that will
increase the risk sensitivity of the
approach and clarify the operation of
the formula when the contractual terms
of the exposures underlying a
securitization permit borrowers to defer
payments of principal and interest, as
described below. To limit potential
burden of implementing the SSFA,
banking organizations that are not
subject to the market risk rule may also
choose to use as an alternative the grossup approach described in section
VIII.H.5 below, provided that they apply
the gross-up approach to all of their
securitization exposures.
Similar to the SFA under the
advanced approaches rule, the SSFA is
a formula that starts with a baseline
derived from the capital requirements
that apply to all exposures underlying
the securitization and then assigns risk
weights based on the subordination
level of an exposure. The agencies
designed the SSFA to apply relatively
higher capital requirements to the more
risky junior tranches of a securitization
that are the first to absorb losses, and
relatively lower requirements to the
most senior exposures.
The SSFA applies a 1,250 percent risk
weight to securitization exposures that
absorb losses up to the amount of
capital that is required for the
underlying exposures under subpart D
of the final rule had those exposures
been held directly by a banking
organization. In addition, the agencies
are implementing a supervisory riskweight floor or minimum risk weight for
a given securitization of 20 percent.
While some commenters requested that
the floor be lowered for certain low-risk
securitization exposures, the agencies
believe that a 20 percent floor is prudent
given the performance of many
securitization exposures during the
recent crisis.
At the inception of a securitization,
the SSFA requires more capital on a
transaction-wide basis than would be
required if the underlying assets had not
been securitized. That is, if the banking
organization held every tranche of a
securitization, its overall capital
requirement would be greater than if the
banking organization held the
underlying assets in portfolio. The
agencies believe this overall outcome is
important in reducing the likelihood of
regulatory capital arbitrage through
securitizations.
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The proposed rule required banking
organizations to use data to assign the
SSFA parameters that are not more than
91 days old. Commenters requested that
the data requirement be amended to
account for securitizations of underlying
assets with longer payment periods,
such as transactions featuring annual or
biannual payments. In response, the
agencies amended this requirement in
the final rule so that data used to
determine SSFA parameters must be the
most currently available data. However,
for exposures that feature payments on
a monthly or quarterly basis, the final
rule requires the data to be no more than
91 calendar days old.
Under the final rule, to use the SSFA,
a banking organization must obtain or
determine the weighted-average risk
weight of the underlying exposures
(KG), as well as the attachment and
detachment points for the banking
organization’s position within the
securitization structure. ‘‘KG,’’ is
calculated using the risk-weighted asset
amounts in the standardized approach
and is expressed as a decimal value
between zero and 1 (that is, an average
risk weight of 100 percent means that
KG would equal 0.08). The banking
organization may recognize the relative
seniority of the exposure, as well as all
cash funded enhancements, in
determining attachment and detachment
points. In addition, a banking
organization must be able to determine
the credit performance of the underlying
exposures.
The commenters expressed concerns
that certain types of data that would be
required to calculate KG may not be
readily available, particularly data
necessary to calculate the weightedaverage capital requirement of
residential mortgages according to the
proposed rule’s standardized approach
for residential mortgages. Some
commenters therefore asked to be able
to use the risk weights under the general
risk-based capital rules for residential
mortgages in the calculation of KG.
Commenters also requested the use of
alternative estimates or conservative
proxy data to implement the SSFA
when a parameter is not readily
available, especially for securitizations
of mortgage exposures. As previously
discussed, the agencies are retaining in
the final rule the existing mortgage
treatment under the general risk-based
capital rules. Accordingly, the agencies
believe that banking organizations
should generally have access to the data
necessary to calculate the SSFA
parameters for mortgage exposures.
Commenters characterized the KG
parameter as not sufficiently risk
sensitive and asked the agencies and the
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62119
FDIC to provide more recognition under
the SSFA with respect to the credit
quality of the underlying assets. Some
commenters observed that the SSFA did
not take into account sequential pay
structures. As a result, some
commenters requested that banking
organizations be allowed to implement
cash-flow models to increase risk
sensitivity, especially given that the
SSFA does not recognize the various
types of cash-flow waterfalls for
different transactions.
In developing the final rule, the
agencies considered the trade-offs
between added risk sensitivity,
increased complexity that would result
from reliance on cash-flow models, and
consistency with standardized approach
risk weights. The agencies believe it is
important to calibrate capital
requirements under the securitization
framework in a manner that is
consistent with the calibration used for
the underlying assets of the
securitization to reduce complexity and
best align capital requirements under
the securitization framework with
requirements for credit exposures under
the standardized approach. As a result,
the agencies have decided to finalize the
KG parameter as proposed.
To make the SSFA more risk-sensitive
and forward-looking, the parameter KG
is modified based on delinquencies
among the underlying assets of the
securitization. The resulting adjusted
parameter is labeled KA. KA is set equal
to the weighted average of the KG value
and a fixed parameter equal to 0.5.
KA = (1 ¥ W) · KG + (0.5 · W)
Under the proposal, the W parameter
equaled the ratio of the sum of the
dollar amounts of any underlying
exposures of the securitization that are
90 days or more past due, subject to a
bankruptcy or insolvency proceeding, in
the process of foreclosure, held as real
estate owned, in default, or have
contractually deferred interest for 90
days or more divided by the ending
balance, measured in dollars, of the
underlying exposures. Commenters
expressed concern that the proposal
would require additional capital for
payment deferrals that are unrelated to
the creditworthiness of the borrower,
and encouraged the agencies and the
FDIC to amend the proposal so that the
numerator of the W parameter would
not include deferrals of interest that are
unrelated to the performance of the loan
or the borrower, as is the case for certain
federally-guaranteed student loans or
certain consumer credit facilities that
allow the borrower to defer principal
and interest payments for the first 12
months following the purchase of a
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funds are disbursed that provide for
period(s) of deferral that are not
initiated based on changes in the
creditworthiness of the borrower. The
agencies believe that the SSFA
appropriately reflects partial
government guarantees because such
guarantees are reflected in KG in the
same manner that they are reflected in
capital requirements for loans held on
balance sheet. For clarity, the agencies
have eliminated the term ‘‘securitized
pool’’ from the final rule. The
calculation of parameter W includes all
underlying exposures of a securitization
transaction.
The agencies believe that, with the
parameter W calibration set equal to 0.5,
the overall capital requirement
produced by the SSFA is sufficiently
The values A of and D denote the
attachment and detachment points,
respectively, for the tranche.
Specifically, A is the attachment point
for the tranche that contains the
securitization exposure and represents
the threshold at which credit losses will
first be allocated to the exposure. This
input is the ratio, as expressed as a
decimal value between zero and one, of
the dollar amount of the securitization
exposures that are subordinated to the
tranche that contains the securitization
exposure held by the banking
organization to the current dollar
amount of all underlying exposures.
Commenters requested that the
agencies and the FDIC recognize
unfunded forms of credit support, such
as excess spread, in the calculation of A.
Commenters also stated that where the
carrying value of an exposure is less
than its par value, the discount to par
for a particular exposure should be
recognized as additional credit
protection. However, the agencies
believe it is prudent to recognize only
funded credit enhancements, such as
overcollateralization or reserve accounts
funded by accumulated cash flows, in
the calculation of parameter A.
Discounts and write-downs can be
related to credit risk or due to other
factors such as interest rate movements
or liquidity. As a result, the agencies do
not believe that discounts or writedowns should be factored into the SSFA
as credit enhancement.
Parameter D is the detachment point
for the tranche that contains the
securitization exposure and represents
the threshold at which credit losses
allocated to the securitization exposure
would result in a total loss of principal.
This input, which is a decimal value
between zero and one, equals the value
of parameter A plus the ratio of the
current dollar amount of the
securitization exposures that are pari
passu with the banking organization’s
securitization exposure (that is, have
equal seniority with respect to credit
risk) to the current dollar amount of all
underlying exposures. The SSFA
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responsive and prudent to ensure
sufficient capital for pools that
demonstrate credit weakness. The entire
specification of the SSFA in the final
rule is as follows:
KSSFA is the risk-based capital
requirement for the securitization
exposure and is a function of three
variables, labeled a, u, and l. The
constant e is the base of the natural
logarithms (which equals 2.71828). The
variables a, u, and l have the following
definitions:
specification is completed by the
constant term p, which is set equal to
0.5 for securitization exposures that are
not resecuritizations, or 1.5 for
resecuritization exposures, and the
variable KA, which is described above.
When parameter D for a securitization
exposure is less than or equal to KA, the
exposure must be assigned a risk weight
of 1,250 percent. When A for a
securitization exposure is greater than
or equal to KA, the risk weight of the
exposure, expressed as a percent, would
equal KSSFA times 1,250. When A is less
than KA and D is greater than KA, the
applicable risk weight is a weighted
average of 1,250 percent and 1,250
percent times KSSFA. As suggested by
commenters, in order to make the
description of the SSFA formula clearer,
the term ‘‘l’’ has been redefined to be the
maximum of 0 and A–KA, instead of the
proposed A–KA. The risk weight would
be determined according to the
following formula:
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product or service. Some commenters
also asserted that the proposed SSFA
would not accurately calibrate capital
requirements for those student loans
with a partial government guarantee.
Another commenter also asked for
clarification on which exposures are in
the securitized pool.
In response to these concerns, the
agencies have decided to explicitly
exclude from the numerator of
parameter W loans with deferral of
principal or interest for (1) federallyguaranteed student loans, in accordance
with the terms of those programs, or (2)
for consumer loans, including nonfederally-guaranteed student loans,
provided that such payments are
deferred pursuant to provisions
included in the contract at the time
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For resecuritizations, banking
organizations must use the SSFA to
measure the underlying securitization
exposure’s contribution to KG. For
example, consider a hypothetical
securitization tranche that has an
attachment point at 0.06 and a
detachment point at 0.07. Then assume
that 90 percent of the underlying pool
of assets were mortgage loans that
qualified for a 50 percent risk weight
and that the remaining 10 percent of the
pool was a tranche of a separate
securitization (where the underlying
exposures consisted of mortgages that
also qualified for a 50 percent weight).
An exposure to this hypothetical
tranche would meet the definition of a
resecuritization exposure. Next, assume
that the attachment point A of the
underlying securitization that is the 10
percent share of the pool is 0.06 and the
detachment point is 0.08. Finally,
assume that none of the underlying
mortgage exposures of either the
hypothetical tranche or the underlying
securitization exposure meet the final
rule definition of ‘‘delinquent.’’
The value of KG for the
resecuritization exposure equals the
weighted average of the two distinct KG
values. For the mortgages that qualify
for the 50 percent risk weight and
represent 90 percent of the
resecuritization, KG equals 0.04 (that is,
50 percent of the 8 percent risk-based
capital standard).
KG,re-securitization = (0.9 · 0.04) + (0.1 ·
KG,securitizaiton)
To calculate the value of KG,securitization
a banking organization would use the
attachment and detachment points of
0.06 and 0.08, respectively. Applying
those input parameters to the SSFA
(together with p = 0.5 and KG = 0.04)
results in a KG,securitization equal to 0.2325.
Substituting this value into the
equation yields:
KG,re-securitization = (0.9 · 0.04) + (0.1 ·
0.2325) = 0.05925
This value of 0.05925 for
KG,re-securitization, would then be used in
the calculation of the risk-based capital
requirement for the tranche of the
resecuritization (where A = 0.06, B =
0.07, and p = 1.5). The result is a risk
weight of 1,172 percent for the tranche
that runs from 0.06 to 0.07. Given that
the attachment point is very close to the
value of KG,re-securitization, the capital
charge is nearly equal to the maximum
risk weight of 1,250 percent.
To apply the securitization framework
to a single tranched exposure that has
been re-tranched, such as some ReREMICs, a banking organization must
apply the SSFA or gross-up approach to
the retranched exposure as if it were
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still part of the structure of the original
securitization transaction. Therefore, a
banking organization implementing the
SSFA or the gross-up approach would
calculate parameters for those
approaches that would treat the
retranched exposure as if it were still
embedded in the original structure of
the transaction while still recognizing
any added credit enhancement provided
by retranching. For example, under the
SSFA a banking organization would
calculate the approach using
hypothetical attachment and
detachment points that reflect the
seniority of the retranched exposure
within the original deal structure, as
well as any additional credit
enhancement provided by retranching
of the exposure. Parameters that depend
on pool-level characteristics, such as the
W parameter under the SSFA, would be
calculated based on the characteristics
of the total underlying exposures of the
initial securitization transaction, not
just the retranched exposure.
5. Gross-Up Approach
Under the final rule, consistent with
the proposal, banking organizations that
are not subject to the market risk rule
may assign risk-weighted asset amounts
to securitization exposures by
implementing the gross-up approach
described in section 43 of the final rule,
which is similar to an existing approach
provided under the general risk-based
capital rules. If the banking organization
chooses to apply the gross-up approach,
it is required to apply this approach to
all of its securitization exposures,
except as otherwise provided for certain
securitization exposures under sections
44 and 45 of the final rule.
The gross-up approach assigns riskweighted asset amounts based on the
full amount of the credit-enhanced
assets for which the banking
organization directly or indirectly
assumes credit risk. To calculate riskweighted assets under the gross-up
approach, a banking organization
determines four inputs: The pro rata
share, the exposure amount, the
enhanced amount, and the applicable
risk weight. The pro rata share is the par
value of the banking organization’s
exposure as a percentage of the par
value of the tranche in which the
securitization exposure resides. The
enhanced amount is the par value of all
the tranches that are more senior to the
tranche in which the exposure resides.
The applicable risk weight is the
weighted-average risk weight of the
underlying exposures in the
securitization as calculated under the
standardized approach.
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Under the gross-up approach, a
banking organization is required to
calculate the credit equivalent amount,
which equals the sum of (1) the
exposure of the banking organization’s
securitization exposure and (2) the pro
rata share multiplied by the enhanced
amount. To calculate risk-weighted
assets for a securitization exposure
under the gross-up approach, a banking
organization is required to assign the
applicable risk weight to the gross-up
credit equivalent amount. As noted
above, in all cases, the minimum risk
weight for securitization exposures is 20
percent.
As discussed above, the agencies
recognize that different capital
requirements are likely to result from
the application of the gross-up approach
as compared to the SSFA. However, the
agencies believe allowing smaller, less
complex banking organizations not
subject to the market risk rule to use the
gross up approach (consistent with past
practice under the existing general riskbased capital rules) is appropriate and
should reduce operational burden for
many banking organizations.
6. Alternative Treatments for Certain
Types of Securitization Exposures
Under the proposal, a banking
organization generally would assign a
1,250 percent risk weight to any
securitization exposure to which the
banking organization does not apply the
SSFA or the gross-up approach.
However, the proposal provided
alternative treatments for certain types
of securitization exposures described
below, provided that the banking
organization knows the composition of
the underlying exposures at all times.
a. Eligible Asset-Backed Commercial
Paper Liquidity Facilities
Under the final rule, consistent with
the proposal and the Basel capital
framework, a banking organization is
permitted to determine the riskweighted asset amount of an eligible
ABCP liquidity facility by multiplying
the exposure amount by the highest risk
weight applicable to any of the
individual underlying exposures
covered by the facility.
b. A Securitization Exposure in a
Second-Loss Position or Better to an
Asset-Backed Commercial Paper
Program
Under the final rule and consistent
with the proposal, a banking
organization may determine the riskweighted asset amount of a
securitization exposure that is in a
second-loss position or better to an
ABCP program by multiplying the
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exposure amount by the higher of 100
percent and the highest risk weight
applicable to any of the individual
underlying exposures of the ABCP
program, provided the exposure meets
the following criteria:
(1) The exposure is not an eligible
ABCP liquidity facility;
(2) The exposure is economically in a
second-loss position or better, and the
first-loss position provides significant
credit protection to the second-loss
position;
(3) The exposure qualifies as
investment grade; and
(4) The banking organization holding
the exposure does not retain or provide
protection for the first-loss position.
The agencies believe that this
approach, which is consistent with the
Basel capital framework, appropriately
and conservatively assesses the credit
risk of non-first-loss exposures to ABCP
programs. The agencies are adopting
this aspect of the proposal, without
change, for purposes of the final rule.
7. Credit Risk Mitigation for
Securitization Exposures
Under the final rule, and consistent
with the proposal, the treatment of
credit risk mitigation for securitization
exposures would differ slightly from the
treatment for other exposures. To
recognize the risk mitigating effects of
financial collateral or an eligible
guarantee or an eligible credit derivative
from an eligible guarantor, a banking
organization that purchases credit
protection uses the approaches for
collateralized transactions under section
37 of the final rule or the substitution
treatment for guarantees and credit
derivatives described in section 36 of
the final rule. In cases of maturity or
currency mismatches, or, if applicable,
lack of a restructuring event trigger, the
banking organization must make any
applicable adjustments to the protection
amount of an eligible guarantee or credit
derivative as required by section 36 for
any hedged securitization exposure. In
addition, for synthetic securitizations,
when an eligible guarantee or eligible
credit derivative covers multiple hedged
exposures that have different residual
maturities, the banking organization is
required to use the longest residual
maturity of any of the hedged exposures
as the residual maturity of all the
hedged exposures. In the final rule, the
agencies are clarifying that a banking
organization is not required to compute
a counterparty credit risk capital
requirement for the credit derivative
provided that this treatment is applied
consistently for all of its OTC credit
derivatives. However, a banking
organization must calculate
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counterparty credit risk if the OTC
credit derivative is a covered position
under the market risk rule.
Consistent with the proposal, a
banking organization that purchases an
OTC credit derivative (other than an nthto-default credit derivative) that is
recognized as a credit risk mitigant for
a securitization exposure that is not a
covered position under the market risk
rule is not required to compute a
separate counterparty credit risk capital
requirement provided that the banking
organization does so consistently for all
such credit derivatives. The banking
organization must either include all or
exclude all such credit derivatives that
are subject to a qualifying master netting
agreement from any measure used to
determine counterparty credit risk
exposure to all relevant counterparties
for risk-based capital purposes. If a
banking organization cannot, or chooses
not to, recognize a credit derivative that
is a securitization exposure as a credit
risk mitigant, the banking organization
must determine the exposure amount of
the credit derivative under the treatment
for OTC derivatives in section 34. In the
final rule, the agencies are clarifying
that if the banking organization
purchases the credit protection from a
counterparty that is a securitization, the
banking organization must determine
the risk weight for counterparty credit
risk according to the securitization
framework. If the banking organization
purchases credit protection from a
counterparty that is not a securitization,
the banking organization must
determine the risk weight for
counterparty credit risk according to
general risk weights under section 32. A
banking organization that provides
protection in the form of a guarantee or
credit derivative (other than an nth-todefault credit derivative) that covers the
full amount or a pro rata share of a
securitization exposure’s principal and
interest must risk weight the guarantee
or credit derivative as if it holds the
portion of the reference exposure
covered by the guarantee or credit
derivative.
8. Nth-to-Default Credit Derivatives
Under the final rule and consistent
with the proposal, the capital
requirement for credit protection
provided through an nth-to-default credit
derivative is determined either by using
the SSFA, or applying a 1,250 percent
risk weight.
A banking organization providing
credit protection must determine its
exposure to an nth-to-default credit
derivative as the largest notional
amount of all the underlying exposures.
When applying the SSFA, the
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attachment point (parameter A) is the
ratio of the sum of the notional amounts
of all underlying exposures that are
subordinated to the banking
organization’s exposure to the total
notional amount of all underlying
exposures. In the case of a first-todefault credit derivative, there are no
underlying exposures that are
subordinated to the banking
organization’s exposure. In the case of a
second-or-subsequent-to default credit
derivative, the smallest (n-1) underlying
exposure(s) are subordinated to the
banking organization’s exposure.
Under the SSFA, the detachment
point (parameter D) is the sum of the
attachment point and the ratio of the
notional amount of the banking
organization’s exposure to the total
notional amount of the underlying
exposures. A banking organization that
does not use the SSFA to calculate a risk
weight for an nth-to-default credit
derivative would assign a risk weight of
1,250 percent to the exposure.
For protection purchased through a
first-to-default derivative, a banking
organization that obtains credit
protection on a group of underlying
exposures through a first-to-default
credit derivative that meets the rules of
recognition for guarantees and credit
derivatives under section 36(b) of the
final rule must determine its risk-based
capital requirement for the underlying
exposures as if the banking organization
synthetically securitized the underlying
exposure with the smallest riskweighted asset amount and had
obtained no credit risk mitigant on the
other underlying exposures. A banking
organization must calculate a risk-based
capital requirement for counterparty
credit risk according to section 34 of the
final rule for a first-to-default credit
derivative that does not meet the rules
of recognition of section 36(b).
For second-or-subsequent-to-default
credit derivatives, a banking
organization that obtains credit
protection on a group of underlying
exposures through a nth-to-default credit
derivative that meets the rules of
recognition of section 36(b) of the final
rule (other than a first-to-default credit
derivative) may recognize the credit risk
mitigation benefits of the derivative
only if the banking organization also has
obtained credit protection on the same
underlying exposures in the form of
first-through-(n-1)-to-default credit
derivatives; or if n-1 of the underlying
exposures have already defaulted. If a
banking organization satisfies these
requirements, the banking organization
determines its risk-based capital
requirement for the underlying
exposures as if the banking organization
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had only synthetically securitized the
underlying exposure with the nth
smallest risk-weighted asset amount and
had obtained no credit risk mitigant on
the other underlying exposures. For a
nth-to-default credit derivative that does
not meet the rules of recognition of
section 36(b), a banking organization
must calculate a risk-based capital
requirement for counterparty credit risk
according to the treatment of OTC
derivatives under section 34 of the final
rule. The agencies are adopting this
aspect of the proposal without change
for purposes of the final rule.
IX. Equity Exposures
The proposal significantly revised the
general risk-based capital rules’
treatment for equity exposures. To
improve risk sensitivity, the final rule
generally follows the same approach to
equity exposures as the proposal, while
providing clarification on investments
in a separate account as detailed below.
In particular, the final rule requires a
banking organization to apply the
SRWA for equity exposures that are not
exposures to an investment fund and
apply certain look-through approaches
to assign risk-weighted asset amounts to
equity exposures to an investment fund.
These approaches are discussed in
greater detail below.
A. Definition of Equity Exposure and
Exposure Measurement
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The agencies are adopting the
proposed definition of equity exposures,
without change, for purposes of the final
rule.179 Under the final rule, a banking
organization is required to determine
the adjusted carrying value for each
equity exposure based on the
approaches described below. For the onbalance sheet component of an equity
exposure, other than an equity exposure
that is classified as AFS where the
banking organization has made an AOCI
opt-out election under section 22(b)(2)
of the final rule, the adjusted carrying
value is a banking organization’s
carrying value of the exposure. For the
on-balance sheet component of an
equity exposure that is classified as AFS
where the banking organization has
179 See the definition of ‘‘equity exposure’’ in
section 2 of the final rule. However, as described
above in section VIII.A of this preamble, the
agencies have adjusted the definition of ‘‘exposure
amount’’ in line with certain requirements
necessary for banking organizations that make an
AOCI opt-out election.
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made an AOCI opt-out election under
section 22(b)(2) of the final rule, the
adjusted carrying value of the exposure
is the banking organization’s carrying
value of the exposure less any net gains
on the exposure that are reflected in the
carrying value but excluded from the
banking organization’s regulatory
capital components. For a commitment
to acquire an equity exposure that is
unconditional, the adjusted carrying
value is the effective notional principal
amount of the exposure multiplied by a
100 percent conversion factor. For a
commitment to acquire an equity
exposure that is conditional, the
adjusted carrying value is the effective
notional principal amount of the
commitment multiplied by (1) a 20
percent conversion factor, for a
commitment with an original maturity
of one year or less or (2) a 50 percent
conversion factor, for a commitment
with an original maturity of over one
year. For the off-balance sheet
component of an equity exposure that is
not an equity commitment, the adjusted
carrying value is the effective notional
principal amount of the exposure, the
size of which is equivalent to a
hypothetical on-balance sheet position
in the underlying equity instrument that
would evidence the same change in fair
value (measured in dollars) for a given
small change in the price of the
underlying equity instrument, minus
the adjusted carrying value of the onbalance sheet component of the
exposure.
The agencies included the concept of
the effective notional principal amount
of the off-balance sheet portion of an
equity exposure to provide a uniform
method for banking organizations to
measure the on-balance sheet equivalent
of an off-balance sheet exposure. For
example, if the value of a derivative
contract referencing the common stock
of company X changes the same amount
as the value of 150 shares of common
stock of company X, for a small change
(for example, 1.0 percent) in the value
of the common stock of company X, the
effective notional principal amount of
the derivative contract is the current
value of 150 shares of common stock of
company X, regardless of the number of
shares the derivative contract
references. The adjusted carrying value
of the off-balance sheet component of
the derivative is the current value of 150
shares of common stock of company X
minus the adjusted carrying value of
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62123
any on-balance sheet amount associated
with the derivative.
B. Equity Exposure Risk Weights
The proposal set forth a SRWA for
equity exposures, which the agencies
have adopted without change in the
final rule. Therefore, under the final
rule, a banking organization determines
the risk-weighted asset amount for each
equity exposure, other than an equity
exposure to an investment fund, by
multiplying the adjusted carrying value
of the equity exposure, or the effective
portion and ineffective portion of a
hedge pair as described below, by the
lowest applicable risk weight in section
52 of the final rule. A banking
organization determines the riskweighted asset amount for an equity
exposure to an investment fund under
section 53 of the final rule. A banking
organization sums risk-weighted asset
amounts for all of its equity exposures
to calculate its aggregate risk-weighted
asset amount for its equity exposures.
Some commenters asserted that
mutual banking organizations, which
are more highly exposed to equity
exposures than traditional depository
institutions, should be permitted to
assign a 100 percent risk weight to their
equity exposures rather than the
proposed 300 percent risk weight for
publicly-traded equity exposures or 400
percent risk weight for non-publicly
traded equity exposures. Some
commenters also argued that a banking
organization’s equity investment in a
banker’s bank should get special
treatment, for instance, exemption from
the 400 percent risk weight or deduction
as an investment in the capital of an
unconsolidated financial institution.
The agencies have decided to retain
the proposed risk weights in the final
rule because they do not believe there
is sufficient justification for a lower risk
weight solely based on the nature of the
institution (for example, mutual banking
organization) holding the exposure. In
addition, the agencies believe that a 100
percent risk weight does not reflect the
inherent risk for equity exposures that
fall under the proposed 300 percent and
400 percent risk-weight categories or
that are subject to deduction as
investments in unconsolidated financial
institutions. The agencies have agreed to
finalize the SRWA risk weights as
proposed, which are summarized below
in Table 24.
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TABLE 24—SIMPLE RISK-WEIGHT APPROACH
Risk weight
(in percent)
Equity exposure
0 ......................
An equity exposure to a sovereign, the Bank for International Settlements, the European Central Bank, the European Commission, the International Monetary Fund, an MDB, and any other entity whose credit exposures receive a zero percent risk
weight under section 32 of the final rule.
An equity exposure to a PSE, Federal Home Loan Bank or Farmer Mac.
• Community development equity exposures.180
• The effective portion of a hedge pair.
• Non-significant equity exposures to the extent that the aggregate adjusted carrying value of the exposures does not exceed
10 percent of tier 1 capital plus tier 2 capital
A significant investment in the capital of an unconsolidated financial institution in the form of common stock that is not deducted under section 22 of the final rule.
A publicly-traded equity exposure (other than an equity exposure that receives a 600 percent risk weight and including the ineffective portion of a hedge pair).
An equity exposure that is not publicly-traded (other than an equity exposure that receives a 600 percent risk weight).
An equity exposure to an investment firm that (i) would meet the definition of a traditional securitization were it not for the primary Federal supervisor’s application of paragraph (8) of that definition and (ii) has greater than immaterial leverage.
20 ....................
100 ..................
250 ..................
300 ..................
400 ..................
600 ..................
Consistent with the proposal, the final
rule defines publicly traded as traded
on: (1) Any exchange registered with the
SEC as a national securities exchange
under section 6 of the Securities
Exchange Act of 1934 (15 U.S.C. 78f); or
(2) any non-U.S.-based securities
exchange that is registered with, or
approved by, a national securities
regulatory authority and that provides a
liquid, two-way market for the
instrument in question. A two-way
market refers to a market where there
are independent bona fide offers to buy
and sell so that a price reasonably
related to the last sales price or current
bona fide competitive bid and offer
quotations can be determined within
one day and settled at that price within
a relatively short time frame conforming
to trade custom.
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C. Non-significant Equity Exposures
Under the final rule, and as proposed,
a banking organization may apply a 100
percent risk weight to certain equity
180 The final rule generally defines these
exposures as exposures that qualify as community
development investments under 12 U.S.C. 24
(Eleventh), excluding equity exposures to an
unconsolidated small business investment company
and equity exposures held through a consolidated
small business investment company described in
section 302 of the Small Business Investment Act
of 1958 (15 U.S.C. 682). Under the proposal, a
savings association’s community development
equity exposure investments was defined to mean
an equity exposure that are designed primarily to
promote community welfare, including the welfare
of low- and moderate-income communities or
families, such as by providing services or jobs, and
excluding equity exposures to an unconsolidated
small business investment company and equity
exposures held through a consolidated small
business investment company described in section
302 of the Small Business Investment Act of 1958
(15 U.S.C. 682). The agencies have determined that
a separate definition for a savings association’s
community development equity exposure is not
necessary and, therefore, the final rule applies one
definition of community development equity
exposure to all types of covered banking
organizations.
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exposures deemed non-significant. Nonsignificant equity exposures means an
equity exposure to the extent that the
aggregate adjusted carrying value of the
exposures does not exceed 10 percent of
the banking organization’s total
capital.181 To compute the aggregate
adjusted carrying value of a banking
organization’s equity exposures for
determining their non-significance, the
banking organization may exclude (1)
equity exposures that receive less than
a 300 percent risk weight under the
SRWA (other than equity exposures
determined to be non-significant); (2)
the equity exposure in a hedge pair with
the smaller adjusted carrying value; and
(3) a proportion of each equity exposure
to an investment fund equal to the
proportion of the assets of the
investment fund that are not equity
exposures. If a banking organization
does not know the actual holdings of the
investment fund, the banking
organization may calculate the
proportion of the assets of the fund that
are not equity exposures based on the
terms of the prospectus, partnership
agreement, or similar contract that
defines the fund’s permissible
investments. If the sum of the
investment limits for all exposure
classes within the fund exceeds 100
percent, the banking organization must
assume that the investment fund invests
to the maximum extent possible in
equity exposures.
To determine which of a banking
organization’s equity exposures qualify
for a 100 percent risk weight based on
non-significance, the banking
organization first must include equity
181 The definition excludes exposures to an
investment firm that (1) meet the definition of
traditional securitization were it not for the primary
Federal regulator’s application of paragraph (8) of
the definition of a traditional securitization and (2)
has greater than immaterial leverage.
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exposures to unconsolidated smallbusiness investment companies, or
those held through consolidated smallbusiness investment companies
described in section 302 of the Small
Business Investment Act of 1958. Next,
it must include publicly-traded equity
exposures (including those held
indirectly through investment funds),
and then it must include non-publiclytraded equity exposures (including
those held indirectly through
investment funds).182
One commenter proposed that certain
exposures, including those to smallbusiness investment companies, should
not be subject to the 10 percent capital
limitation for non-significant equity
exposures and should receive a 100
percent risk weight, consistent with the
treatment of community development
investments. The agencies reflected
upon this comment and determined to
retain the proposed 10 percent limit on
a banking organization’s total capital in
the final rule given the inherent credit
and concentration risks associated with
these exposures.
D. Hedged Transactions
Under the proposal, to determine riskweighted assets under the SRWA, a
banking organization could identify
hedge pairs, which would be defined as
two equity exposures that form an
effective hedge, as long as each equity
exposure is publicly traded or has a
return that is primarily based on a
publicly traded equity exposure. A
banking organization would risk-weight
only the effective and ineffective
portions of a hedge pair rather than the
entire adjusted carrying value of each
exposure that makes up the pair. A few
commenters requested that non-publicly
traded equities be recognized in a
182 See
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62125
The exposures either have the same
remaining maturity or each has a
remaining maturity of at least three
months; the hedge relationship is
formally documented in a prospective
manner (that is, before the banking
organization acquires at least one of the
equity exposures); the documentation
specifies the measure of effectiveness
(E) the banking organization uses for the
hedge relationship throughout the life of
the transaction; and the hedge
relationship has an E greater than or
equal to 0.8. A banking organization
measures E at least quarterly and uses
one of three measures of E described in
the next section: The dollar-offset
method, the variability-reduction
method, or the regression method.
It is possible that only part of a
banking organization’s exposure to a
particular equity instrument is part of a
hedge pair. For example, assume a
banking organization has equity
exposure A with a $300 adjusted
carrying value and chooses to hedge a
portion of that exposure with equity
exposure B with an adjusted carrying
value of $100. Also assume that the
combination of equity exposure B and
$100 of the adjusted carrying value of
equity exposure A form an effective
hedge with an E of 0.8. In this situation,
the banking organization treats $100 of
equity exposure A and $100 of equity
exposure B as a hedge pair, and the
remaining $200 of its equity exposure A
as a separate, stand-alone equity
position. The effective portion of a
hedge pair is calculated as E multiplied
by the greater of the adjusted carrying
values of the equity exposures forming
the hedge pair. The ineffective portion
of a hedge pair is calculated as (1–E)
multiplied by the greater of the adjusted
carrying values of the equity exposures
forming the hedge pair. In the above
example, the effective portion of the
hedge pair is 0.8 × $100 = $80, and the
ineffective portion of the hedge pair is
(1 ¥ 0.8) × $100 = $20.
The value of t ranges from zero to T,
where T is the length of the observation
period for the values of A and B, and is
comprised of shorter values each
labeled t.
The regression method of measuring
effectiveness is based on a regression in
which the change in value of one
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E. Measures of Hedge Effectiveness
As stated above, a banking
organization could determine
effectiveness using any one of three
methods: The dollar-offset method, the
variability-reduction method, or the
regression method. Under the dollaroffset method, a banking organization
determines the ratio of the cumulative
sum of the changes in value of one
equity exposure to the cumulative sum
of the changes in value of the other
equity exposure, termed the ratio of
value change (RVC). If the changes in
the values of the two exposures
perfectly offset each other, the RVC is
–1. If RVC is positive, implying that the
values of the two equity exposures move
in the same direction, the hedge is not
effective and E equals 0. If RVC is
negative and greater than or equal to –1
(that is, between zero and –1), then E
equals the absolute value of RVC. If RVC
is negative and less than –1, then E
equals 2 plus RVC.
The variability-reduction method of
measuring effectiveness compares
changes in the value of the combined
position of the two equity exposures in
the hedge pair (labeled X in the
equation below) to changes in the value
of one exposure as though that one
exposure were not hedged (labeled A).
This measure of E expresses the timeseries variability in X as a proportion of
the variability of A. As the variability
described by the numerator becomes
small relative to the variability
described by the denominator, the
measure of effectiveness improves, but
is bounded from above by a value of
one. E is computed as:
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ER11OC13.007
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hedged transaction under the rule.
Equities that are not publicly traded are
subject to considerable valuation
uncertainty due to a lack of
transparency and are generally far less
liquid than publicly traded equities. The
agencies have therefore determined that
given the potential increased risk
associated with equities that are not
publicly traded, recognition of these
instruments as hedges under the rule is
not appropriate. One commenter
indicated that the test of hedge
effectiveness used in the calculation of
publicly traded equities should be more
risk sensitive in evaluating all
components of the transaction to better
determine the appropriate risk weight.
The examples the commenter
highlighted indicated dissatisfaction
with the assignment of a 100 percent
risk weight to the effective portion of all
hedge pairs. As described further below,
the proposed rule contained three
methodologies for identifying the
measure of effectiveness of an equity
hedge relationship, methodologies
which recognize less-than-perfect
hedges. The proposal assigns a 100
percent risk weight to the effective
portion of a hedge pair because some
hedge pairs involve residual risks. In
developing the standardized approach,
the agencies and the FDIC sought to
balance complexity and risk sensitivity,
which limits the degree of granularity in
hedge recognition. On balance, the
agencies believe that it is more reflective
of a banking organization’s risk profile
to recognize a broader range of hedge
pairs and assign all hedge pairs a 100
percent risk weight than to recognize
only perfect hedges and assign a lower
risk weight. Accordingly, the agencies
are adopting the proposed treatment
without change.
Under the final rule, two equity
exposures form an effective hedge if:
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exposure in a hedge pair is the
dependent variable and the change in
value of the other exposure in the hedge
pair is the independent variable. E
equals the coefficient of determination
of this regression, which is the
proportion of the variation in the
dependent variable explained by
variation in the independent variable.
However, if the estimated regression
coefficient is positive, then the value of
E is zero. Accordingly, E is higher when
the relationship between the values of
the two exposures is closer.
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F. Equity Exposures to Investment
Funds
Under the general risk-based capital
rules, exposures to investments funds
are captured through one of two
methods. These methods are similar to
the alternative modified look-through
approach and the simple modified lookthrough approach described below. The
proposal included an additional option,
referred to in the NPR as the full lookthrough approach. The agencies and the
FDIC proposed this separate treatment
for equity exposures to an investment
fund to ensure that the regulatory
capital treatment for these exposures is
commensurate with the risk. Thus, the
risk-based capital requirement for equity
exposures to investment funds that hold
only low-risk assets would be relatively
low, whereas high-risk exposures held
through investment funds would be
subject to a higher capital requirement.
The final rule implements these three
approaches as proposed and clarifies
that the risk-weight for any equity
exposure to an investment fund must be
no less than 20 percent.
In addition, the final rule clarifies,
generally consistent with prior agency
guidance, that a banking organization
must treat an investment in a separate
account, such as bank-owned life
insurance, as if it were an equity
exposure to an investment fund.183 A
banking organization must use one of
the look-through approaches provided
in section 53 and, if applicable, section
154 of the final rule to determine the
risk-weighted asset amount for such
investments. A banking organization
that purchases stable value protection
on its investment in a separate account
must treat the portion of the carrying
value of its investment in the separate
account attributable to the stable value
protection as an exposure to the
provider of the protection and the
remaining portion as an equity exposure
183 Interagency Statement on the Purchase and
Risk Management of Life Insurance, pp. 19–20,
https://www.federalreserve.gov/boarddocs/srletters/
2004/SR0419a1.pdf.
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to an investment fund. Stable value
protection means a contract where the
provider of the contract pays to the
policy owner of the separate account an
amount equal to the shortfall between
the fair value and cost basis of the
separate account when the policy owner
of the separate account surrenders the
policy. It also includes a contract where
the provider of the contract pays to the
beneficiary an amount equal to the
shortfall between the fair value and
book value of a specified portfolio of
assets.
A banking organization that provides
stable value protection, such as through
a stable value wrap that has provisions
and conditions that minimize the wrap’s
exposure to credit risk of the underlying
assets in the fund, must treat the
exposure as if it were an equity
derivative on an investment fund and
determine the adjusted carrying value of
the exposure as the sum of the adjusted
carrying values of any on-balance sheet
asset component determined according
to section 51(b)(1) and the off-balance
sheet component determined according
to section 51(b)(3). That is, the adjusted
carrying value is the effective notional
principal amount of the exposure, the
size of which is equivalent to a
hypothetical on-balance sheet position
in the underlying equity instrument that
would evidence the same change in fair
value (measured in dollars) given a
small change in the price of the
underlying equity instrument without
subtracting the adjusted carrying value
of the on-balance sheet component of
the exposure as calculated under the
same paragraph. Risk-weighted assets
for such an exposure is determined by
applying one of the three look-through
approaches as provided in section 53
and, if applicable, section 154 of the
final rule.
As discussed further below, under the
final rule, a banking organization
determines the risk-weighted asset
amount for equity exposures to
investment funds using one of three
approaches: The full look-through
approach, the simple modified lookthrough approach, or the alternative
modified look-through approach, unless
the equity exposure to an investment
fund is a community development
equity exposure. The risk-weighted
asset amount for such community
development equity exposures is the
exposure’s adjusted carrying value. If a
banking organization does not use the
full look-through approach, and an
equity exposure to an investment fund
is part of a hedge pair, a banking
organization must use the ineffective
portion of the hedge pair as the adjusted
carrying value for the equity exposure to
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the investment fund. The risk-weighted
asset amount of the effective portion of
the hedge pair is equal to its adjusted
carrying value. A banking organization
could choose which approach to apply
for each equity exposure to an
investment fund.
1. Full Look-Through Approach
A banking organization may use the
full look-through approach only if the
banking organization is able to calculate
a risk-weighted asset amount for each of
the exposures held by the investment
fund. Under the final rule, a banking
organization using the full look-through
approach is required to calculate the
risk-weighted asset amount for its
proportionate ownership share of each
of the exposures held by the investment
fund (as calculated under subpart D of
the final rule) as if the proportionate
ownership share of the adjusted
carrying value of each exposures were
held directly by the banking
organization. The banking
organization’s risk-weighted asset
amount for the exposure to the fund is
equal to (1) the aggregate risk-weighted
asset amount of the exposures held by
the fund as if they were held directly by
the banking organization multiplied by
(2) the banking organization’s
proportional ownership share of the
fund.
2. Simple Modified Look-Through
Approach
Under the simple modified lookthrough approach, a banking
organization sets the risk-weighted asset
amount for its equity exposure to an
investment fund equal to the adjusted
carrying value of the equity exposure
multiplied by the highest applicable risk
weight under subpart D of the final rule
to any exposure the fund is permitted to
hold under the prospectus, partnership
agreement, or similar agreement that
defines the fund’s permissible
investments. The banking organization
may exclude derivative contracts held
by the fund that are used for hedging,
rather than for speculative purposes,
and do not constitute a material portion
of the fund’s exposures.
3. Alternative Modified Look-Through
Approach
Under the alternative modified lookthrough approach, a banking
organization may assign the adjusted
carrying value of an equity exposure to
an investment fund on a pro rata basis
to different risk weight categories under
subpart D of the final rule based on the
investment limits in the fund’s
prospectus, partnership agreement, or
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similar contract that defines the fund’s
permissible investments.
The risk-weighted asset amount for
the banking organization’s equity
exposure to the investment fund is
equal to the sum of each portion of the
adjusted carrying value assigned to an
exposure type multiplied by the
applicable risk weight. If the sum of the
investment limits for all permissible
investments within the fund exceeds
100 percent, the banking organization
must assume that the fund invests to the
maximum extent permitted under its
investment limits in the exposure type
with the highest applicable risk weight
under subpart D and continues to make
investments in the order of the exposure
category with the next highest risk
weight until the maximum total
investment level is reached. If more
than one exposure category applies to
an exposure, the banking organization
must use the highest applicable risk
weight. A banking organization may
exclude derivative contracts held by the
fund that are used for hedging, rather
than for speculative purposes, and do
not constitute a material portion of the
fund’s exposures.
Commenters expressed concerns
regarding the application of the lookthrough approaches where an
investment fund holds securitization
exposures. Specifically, the commenters
indicated a banking organization would
be forced to apply a 1,250 percent risk
weight to investment funds that hold
securitization exposures if the banking
organization does not have the
information required to use one of the
two applicable methods under subpart
D to calculate the risk weight applicable
to a securitization exposure: Gross-up
treatment or the SSFA. According to the
commenters, such an outcome would be
overly punitive and inconsistent with
the generally diversified composition of
investment funds. The agencies
acknowledge that a banking
organization may have some difficulty
obtaining all the information needed to
use the gross-up treatment or SSFA, but
believe that the proposed approach
provides strong incentives for banking
organizations to obtain such
information. As a result, the agencies
are adopting the treatment as proposed.
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X. Insurance-Related Activities
The Board proposed to apply
consolidated regulatory capital
requirements to SLHCs, consistent with
the transfer of supervisory
responsibilities to the Board under Title
III of the Dodd-Frank Act, as well as the
requirements in section 171 of the
Dodd-Frank Act.
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Under the proposal, the consolidated
regulatory capital requirements for
SLHCs would be generally the same as
those proposed for BHCs.184 In addition,
the proposed regulatory capital
requirements would be based on GAAP
consolidated financial statements.
Through this approach, the Board
sought to take into consideration the
unique characteristics, risks, and
activities of SLHCs, while ensuring
compliance with the requirements of the
Dodd-Frank Act. Further, as explained
in the proposal, a uniform approach for
all holding companies was intended to
help mitigate potential competitive
equity issues, limit opportunities for
regulatory arbitrage, and facilitate
comparable treatment of similar risks
across depository institution holding
companies.
The proposal included special
provisions related to the determination
of risk-weighted assets for nonbanking
exposures unique to insurance
underwriting activities. The NPR
extended the approach the agencies and
the FDIC implemented in 2011 in the
general risk-based capital rules for
depository institutions, whereby certain
low-risk exposures that are generally not
held by depository institutions may
receive the capital treatment applicable
under the capital guidelines for BHCs
under limited circumstances.185 This
approach is consistent with section 171
of the Dodd-Frank Act, which requires
that BHCs be subject to capital
requirements that are no less stringent
than those applied to insured depository
institutions. The agencies and the FDIC
solicited comments on all aspects of the
proposed rule, including the treatment
of insurance underwriting activities.
As described above, the final rule
does not apply to SLHCs that are not
covered SLHCs because the Board will
give further consideration to a
framework for consolidated regulatory
capital requirements for SLHCs that are
not covered SLHCs due to the scope of
their insurance underwriting and
commercial activities. Some BHCs and
covered SLHCs currently conduct
insurance underwriting activities,
however, and the final rule for
depository institution holding
companies provides a more risksensitive approach to policy loans, nonguaranteed separate accounts, and
insurance underwriting risk than that
explicitly provided in the standardized
184 See also the Notice of Intent published by the
Board in April, 2011, 76 FR 22662 (April 22, 2011),
in which the Board discussed the possibility of
applying the same consolidated regulatory capital
requirements to savings and holding companies as
those proposed for bank holding companies.
185 See 76 FR 37620 (June 28, 2011).
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approach for depository institutions.
The insurance-specific provisions of the
proposed and final rules and related
comments are discussed below.
A. Policy Loans
The proposal defined a policy loan as
a loan to policyholders under the
provisions of an insurance contract that
is secured by the cash surrender value
or collateral assignment of the related
policy or contract. Under the proposal,
a policy loan would include: (1) A cash
loan, including a loan resulting from
early payment or accelerated payment
benefits, on an insurance contract when
the terms of contract specify that the
payment is a policy loan secured by the
policy; and (2) an automatic premium
loan, which is a loan made in
accordance with policy provisions that
provide that delinquent premium
payments are automatically paid from
the cash value at the end of the
established grace period for premium
payments. The proposal assigned a risk
weight of 20 percent to policy loans.
Several commenters suggested that a
policy loan should be assigned a zero
percent risk weight because an
insurance company that provides a loan
generally retains a right of setoff for the
value of the principal and interest
payments of the policy loan against the
related policy benefits. The Board does
not believe that a zero percent risk
weight is appropriate for policy loans
and continues to believe they should be
treated in a similar manner to a loan
secured by cash collateral, which is
assigned a 20 percent risk weight. The
Board believes assigning a preferential
but non-zero risk weight to a policy loan
is appropriate in light of the fact that
should a borrower default, the resulting
loss to the insurance company is
mitigated by the right to access the cash
surrender value or collateral assignment
of the related policy. Therefore, the final
rule adopts the proposed treatment
without change.
B. Separate Accounts
The proposal provided a specific
treatment for non-guaranteed separate
accounts. Separate accounts are legally
segregated pools of assets owned and
held by an insurance company and
maintained separately from its general
account assets for the benefit of an
individual contract holder, subject to
certain conditions. Under the proposal,
to qualify as a separate account, the
following conditions would have to be
met: (1) The account must be legally
recognized under applicable law; (2) the
assets in the account must be insulated
from general liabilities of the insurance
company under applicable law and
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protected from the insurance company’s
general creditors in the event of the
insurer’s insolvency; (3) the insurance
company must invest the funds within
the account as directed by the contract
holder in designated investment
alternatives or in accordance with
specific investment objectives or
policies; and (4) all investment
performance, net of contract fees and
assessments, must be passed through to
the contract holder, provided that
contracts may specify conditions under
which there may be a minimum
guarantee, but not a ceiling.
The proposal distinguished between
guaranteed and non-guaranteed separate
accounts. Under the proposal, to qualify
as a non-guaranteed separate account,
the insurance company could not
contractually guarantee a minimum
return or account value to the contract
holder, and the insurance company
must not be required to hold reserves for
these separate account assets pursuant
to its contractual obligations on an
associated policy. The proposal
provided for a zero percent risk weight
for assets held in non-guaranteed
separate accounts where all the losses
are passed on to the contract holders
and the insurance company does not
bear the risk of the assets. The proposal
provided that assets held in a separate
account that does not qualify as a nonguaranteed separate account (that is, a
guaranteed separate account) would be
assigned risk weights in the same
manner as other on-balance sheet assets.
The NPR requested comments on this
proposal, including the interaction of
the proposed definition of a separate
account with the state laws and the
nature of the implications of any
differences.
A number of commenters stated that
the proposed definition of a nonguaranteed separate account, including
the proposed criterion that an insurance
company would not be required to hold
reserves for separate account assets
pursuant to its contractual obligations
on an associated policy, is too broad
because, as commenters asserted, state
laws require insurance companies to
hold general account reserves for all
contractual commitments. Accordingly,
the commenters suggested that the
capital requirement for guaranteed
separate accounts should be based on
the value of the guarantee, and not on
the value of the underlying assets,
because of what they characterized as an
inverse relationship between the value
of the underlying assets and the
potential risk of a guarantee being
realized.
The Board continues to believe that it
is appropriate to provide a preferential
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risk-based capital treatment to assets
held in non-guaranteed separate
accounts and is adopting the treatment
of these accounts as proposed. The
criteria for non-guaranteed separate
accounts ensure that a zero percent risk
weight is applied only to those assets for
which contract holders, and not the
consolidated banking organization,
would bear all the losses. Consistent
with the proposal and with the general
risk-based capital rules, the Board is not
at this time providing a preferential
treatment to assets held in guaranteed
separate accounts. The Board believes
that it is consistent with safety and
soundness and with the risk profiles of
banking organizations subject to the
final rule to provide preferential capital
treatment to non-guaranteed separate
accounts while it considers whether and
how to provide a unique treatment to
guaranteed separate accounts. The
Board notes that SLHCs that are not
subject to the final rule because they
meet the exclusion criteria in the
definition of ‘‘covered SLHC’’ typically
have the most material concentrations of
guaranteed separate accounts of all
depository institution holding
companies.
C. Additional Deductions—Insurance
Underwriting Subsidiaries
Consistent with the treatment under
the advanced approaches rule, the Basel
III NPR provided that bank holding
companies and SLHCs would
consolidate and deduct the minimum
regulatory capital requirement of
insurance underwriting subsidiaries
(generally 200 percent of the
subsidiary’s authorized control level as
established by the appropriate state
insurance regulator) from total capital to
reflect the capital needed to cover
insurance risks. The proposed
deduction would be 50 percent from tier
1 capital and 50 percent from tier 2
capital.
A number of commenters stated that
the proposed deduction is not
appropriate for holding companies that
are predominantly engaged in insurance
activities where insurance underwriting
companies contribute the predominant
amount of regulatory capital and assets.
In addition, the commenters asserted
that the insurance risk-based capital
requirements are designed to measure
several specific categories of risk and
that the proposed deduction should not
include asset-specific risks to avoid
double-counting of regulatory capital.
Accordingly, commenters suggested that
the proposed deduction be eliminated
or modified to include only insurance
regulatory capital for non-asset risks,
such as insurance risk and business risk
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for life insurers and underwriting risk
for casualty and property insurers.
Further, the commenters stated that the
proposal did not impose a similar
deduction for other wholly-owned
subsidiaries that are subject to capital
requirements by functional regulators,
such as insured depository institutions
or broker-dealers.
In response to these comments, the
Board has modified the deduction
required for insurance activities to more
closely address insurance underwriting
risk. Specifically, the final rule requires
a banking organization to deduct an
amount equal to the regulatory capital
requirement for insurance underwriting
risks established by the regulator of any
insurance underwriting activities of the
company 50 percent from tier 1 capital
and 50 percent from tier 2 capital.
Accordingly, banking organizations that
calculate their regulatory capital for
insurance underwriting activities using
the National Association of Insurance
Commissioners’ risk-based capital
formulas are required to deduct
regulatory capital attributable to the
categories of the insurance risk-based
capital that do not measure assetspecific risks. For example, for
companies using the life risk-based
capital formula, banking organizations
must deduct the regulatory capital
requirement related to insurance risk
and business risk. For companies using
the property and casualty risk-based
formula, banking organizations must
deduct the regulatory capital
requirement related to underwriting
risk—reserves and underwriting risk—
net written premiums. For companies
using the health risk-based formula,
banking organizations must deduct the
regulatory capital requirement related to
underwriting risk and business risk. In
no case may a banking organization
reduce the capital requirement for
underwriting risk to reflect any
diversification with other risks.
XI. Market Discipline and Disclosure
Requirements
A. Proposed Disclosure Requirements
The agencies have long supported
meaningful public disclosure by
banking organizations with the objective
of improving market discipline and
encouraging sound risk-management
practices. The BCBS introduced public
disclosure requirements under Pillar 3
of Basel II, which is designed to
complement the minimum capital
requirements and the supervisory
review process by encouraging market
discipline through enhanced and
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meaningful public disclosure.186 The
BCBS introduced additional disclosure
requirements in Basel III, which, under
the final rule, apply to banking
organizations as discussed herein.187
The agencies and the FDIC received a
limited number of comments on the
proposed disclosure requirements. The
commenters expressed some concern
that the proposed requirements would
be extended to apply to smaller banking
organizations. As discussed further
below, the agencies and the FDIC
proposed the disclosure requirements
for banking organizations with $50
billion or more in assets and believe
they are most appropriate for these
companies. The agencies believe that
the proposed disclosure requirements
strike the appropriate balance between
the market benefits of disclosure and the
additional burden to a banking
organization that provides the
disclosures, and therefore have adopted
the requirements as proposed, with
minor clarification with regard to timing
of disclosures as discussed further
below.
The public disclosure requirements
under section 62 of the final rule apply
only to banking organizations with total
consolidated assets of $50 billion or
more that are not a consolidated
subsidiary of a BHC, covered SLHC, or
depository institution that is subject to
these disclosure requirements or a
subsidiary of a non-U.S. banking
organization that is subject to
comparable public disclosure
requirements in its home jurisdiction or
an advanced approaches banking
organization making public disclosures
pursuant to section 172 of the final rule.
An advanced approaches banking
organization that meets the $50 billion
asset threshold, but that has not
received approval from its primary
Federal supervisor to exit parallel run,
must make the disclosures described in
sections 62 and 63 of the final rule. The
agencies note that the asset threshold of
$50 billion is consistent with the
threshold established by section 165 of
the Dodd-Frank Act relating to
enhanced supervision and prudential
standards for certain banking
organizations.188 A banking
186 The agencies and the FDIC incorporated the
BCBS disclosure requirements into the advanced
approaches rule in 2007. See 72 FR 69288, 69432
(December 7, 2007).
187 In June 2012, the BCBS adopted Pillar 3
disclosure requirements in a paper titled
‘‘Composition of Capital Disclosure Requirements,’’
available at https://www.bis.org/publ/bcbs221.pdf.
The agencies anticipate incorporating these
disclosure requirements through a separate notice
and comment period.
188 See section 165(a) of the Dodd-Frank Act (12
U.S.C. 5365(a)). The Dodd-Frank Act provides that
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62129
organization may be able to fulfill some
of the disclosure requirements by
relying on similar disclosures made in
accordance with federal securities law
requirements. In addition, a banking
organization may use information
provided in regulatory reports to fulfill
certain disclosure requirements. In these
situations, a banking organization is
required to explain any material
differences between the accounting or
other disclosures and the disclosures
required under the final rule.
A banking organization’s exposure to
risks and the techniques that it uses to
identify, measure, monitor, and control
those risks are important factors that
market participants consider in their
assessment of the banking organization.
Accordingly, a banking organization
must have a formal disclosure policy
approved by its board of directors that
addresses the banking organization’s
approach for determining the
disclosures it should make. The policy
should address the associated internal
controls, disclosure controls, and
procedures. The board of directors and
senior management should ensure the
appropriate review of the disclosures
and that effective internal controls,
disclosure controls, and procedures are
maintained. One or more senior officers
of the banking organization must attest
that the disclosures meet the
requirements of this final rule.
A banking organization must decide
the relevant disclosures based on a
materiality concept. Information is
regarded as material for purposes of the
disclosure requirements in the final rule
if the information’s omission or
misstatement could change or influence
the assessment or decision of a user
relying on that information for the
purpose of making investment
decisions.
fourth calendar quarter, provided any
significant changes are disclosed in the
interim. The agencies acknowledge that
the timing of disclosures under the
federal banking laws may not always
coincide with the timing of disclosures
required under other federal laws,
including disclosures required under
the federal securities laws and their
implementing regulations by the SEC.
For calendar quarters that do not
correspond to fiscal year end, the
agencies consider those disclosures that
are made within 45 days of the end of
the calendar quarter (or within 60 days
for the limited purpose of the banking
organization’s first reporting period in
which it is subject to the rule’s
disclosure requirements) as timely. In
general, where a banking organization’s
fiscal year-end coincides with the end of
a calendar quarter, the agencies consider
qualitative and quantitative disclosures
to be timely if they are made no later
than the applicable SEC disclosure
deadline for the corresponding Form
10–K annual report. In cases where an
institution’s fiscal year end does not
coincide with the end of a calendar
quarter, the primary Federal supervisor
would consider the timeliness of
disclosures on a case-by-case basis. In
some cases, management may determine
that a significant change has occurred,
such that the most recent reported
amounts do not reflect the banking
organization’s capital adequacy and risk
profile. In those cases, a banking
organization needs to disclose the
general nature of these changes and
briefly describe how they are likely to
affect public disclosures going forward.
A banking organization should make
these interim disclosures as soon as
practicable after the determination that
a significant change has occurred.
B. Frequency of Disclosures
Consistent with the agencies’
longstanding requirements for robust
quarterly disclosures in regulatory
reports, and considering the potential
for rapid changes in risk profiles, the
final rule requires that a banking
organization provide timely public
disclosures after each calendar quarter.
However, qualitative disclosures that
provide a general summary of a banking
organization’s risk-management
objectives and policies, reporting
system, and definitions may be
disclosed annually after the end of the
C. Location of Disclosures and Audit
Requirements
the Board may, upon the recommendation of the
Financial Stability Oversight Council, increase the
$50 billion asset threshold for the application of the
resolution plan, concentration limit, and credit
exposure report requirements. See 12 U.S.C.
5365(a)(2)(B).
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The disclosures required under the
final rule must be publicly available (for
example, included on a public Web site)
for each of the last three years or such
shorter time period beginning when the
banking organization became subject to
the disclosure requirements. For
example, a banking organization that
begins to make public disclosures in the
first quarter of 2015 must make all of its
required disclosures publicly available
until the first quarter of 2018, after
which it must make its required
disclosures for the previous three years
publicly available. Except as discussed
below, management has some discretion
to determine the appropriate medium
and location of the disclosure.
Furthermore, a banking organization has
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flexibility in formatting its public
disclosures.
The agencies encourage management
to provide all of the required disclosures
in one place on the entity’s public Web
site and the agencies anticipate that the
public Web site address would be
reported in a banking organization’s
regulatory report. However, a banking
organization may provide the
disclosures in more than one public
financial report or other regulatory
reports (for example, in Management’s
Discussion and Analysis included in
SEC filings), provided that the banking
organization publicly provides a
summary table specifically indicating
the location(s) of all such disclosures
(for example, regulatory report
schedules, page numbers in annual
reports). The agencies expect that
disclosures of common equity tier 1, tier
1, and total capital ratios would be
tested by external auditors as part of the
financial statement audit.
D. Proprietary and Confidential
Information
The agencies believe that the
disclosure requirements strike an
appropriate balance between the need
for meaningful disclosure and the
protection of proprietary and
confidential information.189
Accordingly, the agencies believe that
banking organizations would be able to
provide all of these disclosures without
revealing proprietary and confidential
information. Only in rare circumstances
might disclosure of certain items of
information required by the final rule
compel a banking organization to reveal
confidential and proprietary
information. In these unusual situations,
if a banking organization believes that
disclosure of specific commercial or
financial information would
compromise its position by making
public information that is either
proprietary or confidential in nature, the
banking organization will not be
required to disclose those specific items
under the rule’s periodic disclosure
requirement. Instead, the banking
organization must disclose more general
information about the subject matter of
the requirement, together with the fact
that, and the reason why, the specific
items of information have not been
disclosed. This provision applies only
to those disclosures included in this
189 Proprietary information encompasses
information that, if shared with competitors, would
render a banking organization’s investment in these
products/systems less valuable, and, hence, could
undermine its competitive position. Information
about customers is often confidential, in that it is
provided under the terms of a legal agreement or
counterparty relationship.
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final rule and does not apply to
disclosure requirements imposed by
accounting standards, other regulatory
agencies, or under other requirements of
the agencies.
E. Specific Public Disclosure
Requirements
The public disclosure requirements
are designed to provide important
information to market participants on
the scope of application, capital, risk
exposures, risk assessment processes,
and, thus, the capital adequacy of the
institution. The agencies note that the
substantive content of the tables is the
focus of the disclosure requirements,
not the tables themselves. The table
numbers below refer to the table
numbers in section 63 of the final rule.
A banking organization must make the
disclosures described in Tables 1
through 10.190
Table 1 disclosures, ‘‘Scope of
Application,’’ name the top corporate
entity in the group to which subpart D
of the final rule applies and include a
brief description of the differences in
the basis for consolidating entities for
accounting and regulatory purposes, as
well as a description of any restrictions,
or other major impediments, on transfer
of funds or total capital within the
group. These disclosures provide the
basic context underlying regulatory
capital calculations.
Table 2 disclosures, ‘‘Capital
Structure,’’ provide summary
information on the terms and conditions
of the main features of regulatory capital
instruments, which allow for an
evaluation of the quality of the capital
available to absorb losses within a
banking organization. A banking
organization also must disclose the total
amount of common equity tier 1, tier 1
and total capital, with separate
disclosures for deductions and
adjustments to capital. The agencies
expect that many of these disclosure
requirements would be captured in
revised regulatory reports.
Table 3 disclosures, ‘‘Capital
Adequacy,’’ provide information on a
banking organization’s approach for
categorizing and risk weighting its
exposures, as well as the amount of total
risk-weighted assets. The Table also
includes common equity tier 1, and tier
1 and total risk-based capital ratios for
the top consolidated group, and for each
depository institution subsidiary.
Table 4 disclosures, ‘‘Capital
Conservation Buffer,’’ require a banking
190 Other public disclosure requirements would
continue to apply, such as federal securities law,
and regulatory reporting requirements for banking
organizations.
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organization to disclose the capital
conservation buffer, the eligible retained
income and any limitations on capital
distributions and certain discretionary
bonus payments, as applicable.
Disclosures in Tables 5, ‘‘Credit Risk:
General Disclosures,’’ 6, ‘‘General
Disclosure for Counterparty Credit RiskRelated Exposures,’’ and 7, ‘‘Credit Risk
Mitigation,’’ relate to credit risk,
counterparty credit risk and credit risk
mitigation, respectively, and provide
market participants with insight into
different types and concentrations of
credit risk to which a banking
organization is exposed and the
techniques it uses to measure, monitor,
and mitigate those risks. These
disclosures are intended to enable
market participants to assess the credit
risk exposures of the banking
organization without revealing
proprietary information.
Table 8 disclosures, ‘‘Securitization,’’
provide information to market
participants on the amount of credit risk
transferred and retained by a banking
organization through securitization
transactions, the types of products
securitized by the organization, the risks
inherent in the organization’s
securitized assets, the organization’s
policies regarding credit risk mitigation,
and the names of any entities that
provide external credit assessments of a
securitization. These disclosures
provide a better understanding of how
securitization transactions impact the
credit risk of a banking organization. For
purposes of these disclosures,
‘‘exposures securitized’’ include
underlying exposures transferred into a
securitization by a banking organization,
whether originated by the banking
organization or purchased from third
parties, and third-party exposures
included in sponsored programs.
Securitization transactions in which the
originating banking organization does
not retain any securitization exposure
are shown separately and are only
reported for the year of inception of the
transaction.
Table 9 disclosures, ‘‘Equities Not
Subject to Subpart F of this Part,’’
provide market participants with an
understanding of the types of equity
securities held by the banking
organization and how they are valued.
These disclosures also provide
information on the capital allocated to
different equity products and the
amount of unrealized gains and losses.
Table 10 disclosures, ‘‘Interest Rate
Risk for Non-trading Activities,’’ require
a banking organization to provide
certain quantitative and qualitative
disclosures regarding the banking
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organization’s management of interest
rate risks.
XII. Risk-weighted Assets—
Modifications to the Advanced
Approaches
In the Advanced Approaches NPR,
the agencies and the FDIC proposed
revisions to the advanced approaches
rule to incorporate certain aspects of
Basel III, as well as the requirements
introduced by the BCBS in the 2009
Enhancements 191 and subsequent
consultative papers. In accordance with
Basel III, the proposal sought to require
advanced approaches banking
organizations to hold more appropriate
levels of capital for counterparty credit
risk, CVA, and wrong-way risk.
Consistent with the 2009
Enhancements, the agencies and the
FDIC proposed to strengthen the riskbased capital requirements for certain
securitization exposures by requiring
banking organizations that are subject to
the advanced approaches rule to
conduct more rigorous credit analysis of
securitization exposures and to enhance
the disclosure requirements related to
those exposures.
The agencies and the FDIC also
proposed revisions to the advanced
approaches rule that are consistent with
the requirements of section 939A of the
Dodd-Frank Act.192 The agencies and
the FDIC proposed to remove references
to ratings from certain defined terms
under the advanced approaches rule, as
well as the ratings-based approach for
securitization exposures, and replace
these provisions with alternative
standards of creditworthiness. The
proposed rule also contained a number
of proposed technical amendments to
clarify or adjust existing requirements
under the advanced approaches rule.
The Board also proposed to apply the
advanced approaches rule and the
market risk rule to SLHCs, and the FDIC
and OCC proposed to apply the market
risk rule to state and Federal savings
associations, respectively.
This section of the preamble describes
the proposals in the Advanced
Approaches NPR, comments received
on those proposals, and the revisions to
the advanced approaches rule reflected
in the final rule.
In many cases, the comments received
on the Standardized Approach NPR
were also relevant to the proposed
changes to the advanced approaches
framework. The agencies generally took
a consistent approach towards
191 See ‘‘Enhancements to the Basel II framework’’
(July 2009), available at https://www.bis.org/publ/
bcbs157.htm.
192 See section 939A of Dodd-Frank Act (15
U.S.C. 78o–7 note).
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addressing the comments with respect
to the standardized approach and the
advanced approaches rule. Banking
organizations that are or would be
subject to the advanced approaches rule
should refer to the relevant sections of
the discussion of the standardized
approach for further discussion of these
comments.
One commenter raised concerns about
the use of models in determining
regulatory capital requirements and
encouraged the agencies and the FDIC to
conduct periodic validation of banking
organizations’ models for capital
adequacy and require modification if
necessary. Consistent with the current
advanced approaches rule, the final rule
requires a banking organization to
validate its models used to determine
regulatory capital requirements on an
ongoing basis. This validation must
include an evaluation of conceptual
soundness; an ongoing monitoring
process that includes verification of
processes and benchmarking; and an
outcomes analysis process that includes
backtesting. Under section 123 of the
final rule, a banking organization’s
primary Federal supervisor may require
the banking organization to calculate its
advanced approaches risk-weighted
assets according to modifications
provided by the supervisor if the
supervisor determines that the banking
organization’s advanced approaches
total risk-weighted assets are not
commensurate with its credit, market,
operational or other risks.
Other commenters suggested that the
agencies and the FDIC interpret section
171 of the Dodd-Frank Act narrowly
with regard to the advanced approaches
framework. The agencies have adopted
the approach taken in the proposed rule
because they believe that the approach
provides clear, consistent minimum
requirements across institutions that
comply with the requirements of section
171.
A. Counterparty Credit Risk
The recent financial crisis highlighted
certain aspects of the treatment of
counterparty credit risk under the Basel
II framework that were inadequate, and
of banking organizations’ risk
management of counterparty credit risk
that were insufficient. The Basel III
revisions were intended to address both
areas of weakness by ensuring that all
material on- and off-balance sheet
counterparty risks, including those
associated with derivative-related
exposures, are appropriately
incorporated into banking organizations’
risk-based capital ratios. In addition,
new risk-management requirements in
Basel III strengthen the oversight of
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counterparty credit risk exposures. The
proposed rule included counterparty
credit risk revisions in a manner
generally consistent with the Basel III
revisions to international standards,
modified to incorporate alternative
standards to the use of credit ratings.
The discussion below highlights the
proposed revisions, industry comments,
and outcome of the final rule.
1. Recognition of Financial Collateral
a. Financial Collateral
The EAD adjustment approach under
section 132 of the proposed rules
permitted a banking organization to
recognize the credit risk mitigation
benefits of financial collateral by
adjusting the EAD rather than the loss
given default (LGD) of the exposure for
repo-style transactions, eligible margin
loans and OTC derivative contracts. The
permitted methodologies for recognizing
such benefits included the collateral
haircut approach, simple VaR approach
and the IMM.
Consistent with Basel III, the
Advanced Approaches NPR proposed
certain modifications to the definition of
financial collateral. For example, the
definition of financial collateral was
modified so that resecuritizations would
no longer qualify as financial
collateral.193 Thus, resecuritization
collateral could not be used to adjust the
EAD of an exposure. The agencies
believe that this treatment is appropriate
because resecuritizations have been
shown to have more market value
volatility than other types of financial
collateral.
The proposed rule also removed
conforming residential mortgages from
the definition of financial collateral. As
a result, a banking organization would
no longer be able to recognize the credit
risk mitigation benefit of such
instruments through an adjustment to
EAD. Consistent with the Basel III
framework, the agencies and the FDIC
proposed to exclude all debt securities
that are not investment grade from the
definition of financial collateral. As
discussed in section VII.F of this
preamble, the proposed rule revised the
definition of ‘‘investment grade’’ for the
advanced approaches rule and proposed
conforming changes to the market risk
rule.
As discussed in section VIII.F of the
preamble, the agencies believe that the
193 Under the proposed rule, a securitization in
which one or more of the underlying exposures is
a securitization position would be a
resecuritization. A resecuritization position under
the proposal meant an on- or off-balance sheet
exposure to a resecuritization, or an exposure that
directly or indirectly references a securitization
exposure.
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additional collateral types suggested by
commenters are not appropriate forms
of financial collateral because they
exhibit increased variation and credit
risk, and are relatively more speculative
than the recognized forms of financial
collateral under the proposal. In some
cases, the assets suggested by
commenters for eligibility as financial
collateral were precisely the types of
assets that became illiquid during the
recent financial crisis. As a result, the
agencies have retained the definition of
financial collateral as proposed.
b. Revised Supervisory Haircuts
Securitization exposures have
increased levels of volatility relative to
other types of financial collateral. To
address this issue, consistent with Basel
III, the proposal incorporated new
standardized supervisory haircuts for
securitization exposures in the EAD
adjustment approach based on the credit
quality of the exposure. Consistent with
section 939A of the Dodd-Frank Act, the
proposed rule set out an alternative
approach to assigning standard
one year, 8.0 percent for maturities
greater than one year but less than or
equal to five years, and 16.0 percent for
maturities greater than five years,
consistent with Table 25 below. The
agencies believe that the revised
haircuts better reflect the collateral’s
credit quality and an appropriate
differentiation based on the collateral’s
residual maturity.
Consistent with the proposal, under
the final rule, supervisory haircuts for
exposures to sovereigns, GSEs, public
sector entities, depository institutions,
foreign banks, credit unions, and
corporate issuers are calculated based
upon the risk weights for such
exposures described under section 32 of
the final rule. The final rule also
clarifies that if a banking organization
lends instruments that do not meet the
definition of financial collateral, such as
non-investment-grade corporate debt
securities or resecuritization exposures,
the haircut applied to the exposure must
be 25 percent.
supervisory haircuts for securitization
exposures, and amended the standard
supervisory haircuts for other types of
financial collateral to remove the
references to credit ratings.
Some commenters proposed limiting
the maximum haircut for non-sovereign
issuers that receive a 100 percent risk
weight to 12 percent, and more
specifically assigning a lower haircut
than 25 percent for financial collateral
in the form of an investment-grade
corporate debt security that has a
shorter residual maturity. The
commenters asserted that these haircuts
conservatively correspond to the
existing rating categories and result in
greater alignment with the Basel
framework. As discussed in section
VIII.F of the preamble, in the final rule,
the agencies have revised the standard
supervisory market price volatility
haircuts for financial collateral issued
by non-sovereign issuers with a risk
weight of 100 percent from 25.0 percent
to 4.0 percent for maturities of less than
TABLE 25—STANDARD SUPERVISORY MARKET PRICE VOLATILITY HAIRCUTS 1
Haircut (in percent) assigned based on:
Sovereign issuers
risk weight under section 32 2
(in percent)
Residual maturity
Zero
Less than or equal to 1 year .......................
Greater than 1 year and less than or equal
to 5 years .................................................
Greater than 5 years ....................................
20 or 50
Investment-grade
securitization
exposures
(in percent)
Non-sovereign issuers
risk weight under section 32
(in percent)
100
20
50
100
0.5
1.0
15.0
1.0
2.0
4.0
4.0
2.0
4.0
3.0
6.0
15.0
15.0
4.0
8.0
6.0
12.0
8.0
16.0
12.0
24.0
Main index equities (including convertible bonds) and gold .........................................
15.0
Other publicly traded equities (including convertible bonds) .........................................
25.0
Mutual funds ..................................................................................................................
Highest haircut applicable to any security in which the
fund can invest.
Cash collateral held .......................................................................................................
Zero
Other exposure types ....................................................................................................
25.0
1 The
market price volatility haircuts in Table 25 are based on a 10 business-day holding period.
2 Includes a foreign PSE that receives a zero percent risk weight.
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2. Holding Periods and the Margin
Period of Risk
As noted in the proposal, during the
recent financial crisis, many financial
institutions experienced significant
delays in settling or closing out
collateralized transactions, such as repostyle transactions and collateralized
OTC derivative contracts. The assumed
holding period for collateral in the
collateral haircut and simple VaR
approaches and the margin period of
risk in the IMM proved to be inadequate
for certain transactions and netting
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sets.194 It also did not reflect the
difficulties and delays experienced by
institutions when settling or liquidating
194 Under the advanced approaches rule, the
margin period of risk means, with respect to a
netting set subject to a collateral agreement, the
time period from the most recent exchange of
collateral with a counterparty until the next
required exchange of collateral plus the period of
time required to sell and realize the proceeds of the
least liquid collateral that can be delivered under
the terms of the collateral agreement and, where
applicable, the period of time required to re-hedge
the resulting market risk, upon the default of the
counterparty.
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collateral during a period of financial
stress.
Consistent with Basel III, the
proposed rule would have amended the
advanced approaches rule to
incorporate adjustments to the holding
period in the collateral haircut and
simple VaR approaches, and to the
margin period of risk in the IMM that a
banking organization may use to
determine its capital requirement for
repo-style transactions, OTC derivative
transactions, and eligible margin loans,
with respect to large netting sets, netting
sets involving illiquid collateral or
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including OTC derivatives that could
not easily be replaced, or two margin
disputes within a netting set over the
previous two quarters that last for a
certain length of time. For cleared
transactions, which are discussed
below, the agencies and the FDIC
proposed not to require a banking
organization to adjust the holding
period or margin period of risk upward
when determining the capital
requirement for its counterparty credit
risk exposures to the CCP, which is also
consistent with Basel III.
One commenter asserted that the
proposed triggers for the increased
margin period of risk were not in the
spirit of the advanced approaches rule,
which is intended to be more risk
sensitive than the general risk-based
capital rules. Another commenter
asserted that banking organizations
should be permitted to increase the
holding period or margin period of risk
by one or more business days, but not
be required to increase it to the full
period required under the proposal (20
business days or at least double the
margin period of risk).
The agencies believe the triggers set
forth in the proposed rule, as well as the
increased holding period or margin
period of risk are empirical indicators of
increased risk of delay or failure of
close-out on the default of a
counterparty. The goal of risk sensitivity
would suggest that modifying these
indicators is not warranted and could
lead to increased risks to the banking
system. Accordingly, the final rule
adopts these features as proposed.
3. Internal Models Methodology
Consistent with Basel III, the
proposed rule would have amended the
advanced approaches rule so that the
capital requirement for IMM exposures
is equal to the larger of the capital
requirement for those exposures
calculated using data from the most
recent three-year period and data from
a three-year period that contains a
period of stress reflected in the credit
default spreads of the banking
organization’s counterparties. The
proposed rule defined an IMM exposure
as a repo-style transaction, eligible
margin loan, or OTC derivative contract
for which a banking organization
calculates EAD using the IMM.
The proposed rule would have
required a banking organization to
demonstrate to the satisfaction of the
banking organization’s primary Federal
supervisor at least quarterly that the
stress period it uses for the IMM
coincides with increased CDS or other
credit spreads of its counterparties and
to have procedures in place to evaluate
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the effectiveness of its stress calibration.
These procedures would have been
required to include a process for using
benchmark portfolios that are
vulnerable to the same risk factors as the
banking organization’s portfolio. In
addition, under the proposal, the
primary Federal supervisor could
require a banking organization to
modify its stress calibration if the
primary Federal supervisor believes that
another calibration better reflects the
actual historic losses of the portfolio.
Consistent with Basel III and the
current advanced approaches rule, the
proposed rule would have required a
banking organization to establish a
process for initial validation and annual
review of its internal models. As part of
the process, the proposed rule would
have required a banking organization to
have a backtesting program for its model
that includes a process by which
unacceptable model performance is
identified and remedied. In addition, a
banking organization would have been
required to multiply the expected
positive exposure (EPE) of a netting set
by the default scaling factor alpha (set
equal to 1.4) in calculating EAD. The
primary Federal supervisor could
require the banking organization to set
a higher default scaling factor based on
the past performance of the banking
organization’s internal model.
The proposed rule would have
required a banking organization to have
policies for the measurement,
management, and control of collateral,
including the reuse of collateral and
margin amounts, as a condition of using
the IMM. Under the proposal, a banking
organization would have been required
to have a comprehensive stress testing
program for the IMM that captures all
credit exposures to counterparties and
incorporates stress testing of principal
market risk factors and the
creditworthiness of its counterparties.
Basel III provided that a banking
organization could capture within its
internal model the effect on EAD of a
collateral agreement that requires
receipt of collateral when the exposure
to the counterparty increases. Basel II
also contained a ‘‘shortcut’’ method to
provide a banking organization whose
internal model did not capture the
effects of collateral agreements with a
method to recognize some benefit from
the collateral agreement. Basel III
modifies the ‘‘shortcut’’ method for
capturing the effects of collateral
agreements by setting effective EPE to a
counterparty as the lesser of the
following two exposure calculations: (1)
The exposure without any held or
posted margining collateral, plus any
collateral posted to the counterparty
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independent of the daily valuation and
margining process or current exposure,
or (2) an add-on that reflects the
potential increase of exposure over the
margin period of risk plus the larger of
(i) the current exposure of the netting
set reflecting all collateral received or
posted by the banking organization
excluding any collateral called or in
dispute; or (ii) the largest net exposure
(including all collateral held or posted
under the margin agreement) that would
not trigger a collateral call. The add-on
would be computed as the largest
expected increase in the netting set’s
exposure over any margin period of risk
in the next year. The proposed rule
included the Basel III modification of
the ‘‘shortcut’’ method.
The final rule adopts all the proposed
requirements discussed above with two
modifications. With respect to the
proposed requirement that a banking
organization must demonstrate on a
quarterly basis to its primary Federal
supervisor the appropriateness of its
stress period, under the final rule, the
banking organization must instead
demonstrate at least quarterly that the
stress period coincides with increased
CDS or other credit spreads of the
banking organization’s counterparties,
and must maintain documentation of
such demonstration. In addition, the
formula for the ‘‘shortcut’’ method has
been modified to clarify that the add-on
is computed as the expected increase in
the netting set’s exposure over the
margin period of risk.
a. Recognition of Wrong-Way Risk
The recent financial crisis highlighted
the interconnectedness of large financial
institutions through an array of complex
transactions. In recognition of this
interconnectedness and to mitigate the
risk of contagion from the banking
sector to the broader financial system
and the general economy, Basel III
includes enhanced requirements for the
recognition and treatment of wrong-way
risk in the IMM. The proposed rule
defined wrong-way risk as the risk that
arises when an exposure to a particular
counterparty is positively correlated
with the probability of default of that
counterparty.
The proposed rule provided
enhancements to the advanced
approaches rule that require banking
organizations’ risk-management
procedures to identify, monitor, and
control wrong-way risk throughout the
life of an exposure. The proposed rule
required these risk-management
procedures to include the use of stress
testing and scenario analysis. In
addition, where a banking organization
has identified an IMM exposure with
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specific wrong-way risk, the banking
organization would be required to treat
that transaction as its own netting set.
The proposed rule defined specific
wrong-way risk as a type of wrong-way
risk that arises when either the
counterparty and issuer of the collateral
supporting the transaction, or the
counterparty and the reference asset of
the transaction, are affiliates or are the
same entity.
In addition, under the proposal,
where a banking organization has
identified an OTC derivative
transaction, repo-style transaction, or
eligible margin loan with specific
wrong-way risk for which the banking
organization otherwise applies the IMM,
the banking organization would set the
probability of default (PD) of the
counterparty and a LGD equal to 100
percent. The banking organization
would then enter these parameters into
the appropriate risk-based capital
formula specified in Table 1 of section
131 of the proposed rule, and multiply
the output of the formula (K) by an
alternative EAD based on the
transaction type, as follows:
(1) For a purchased credit derivative,
EAD would be the fair value of the
underlying reference asset of the credit
derivative contract;
(2) For an OTC equity derivative,195
EAD would be the maximum amount
that the banking organization could lose
if the fair value of the underlying
reference asset decreased to zero;
(3) For an OTC bond derivative (that
is, a bond option, bond future, or any
other instrument linked to a bond that
gives rise to similar counterparty credit
risks), EAD would be the smaller of the
notional amount of the underlying
reference asset and the maximum
amount that the banking organization
could lose if the fair value of the
underlying reference asset decreased to
zero; and
(4) For repo-style transactions and
eligible margin loans, EAD would be
calculated using the formula in the
collateral haircut approach of section
132 of the final rule and with the
estimated value of the collateral
substituted for the parameter C in the
equation.
The final rule adopts the proposed
requirements regarding wrong-way risk
discussed above.
b. Increased Asset Value Correlation
Factor
To recognize the correlation of
financial institutions’ creditworthiness
195 Under the final rule, equity derivatives that
are call options are not be subject to a counterparty
credit risk capital requirement for specific wrongway risk.
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attributable to similar sensitivities to
common risk factors, the agencies and
the FDIC proposed to incorporate the
Basel III increase in the correlation
factor used in the formulas provided in
Table 1 of section 131 of the proposed
rule for certain wholesale exposures.
Under the proposed rule, banking
organizations would apply a multiplier
of 1.25 to the correlation factor for
wholesale exposures to unregulated
financial institutions that generate a
majority of their revenue from financial
activities, regardless of asset size. This
category would include highly
leveraged entities, such as hedge funds
and financial guarantors. The proposal
also included a definition of ‘‘regulated
financial institution,’’ meaning a
financial institution subject to
consolidated supervision and regulation
comparable to that imposed on certain
U.S. financial institutions, namely
depository institutions, depository
institution holding companies, nonbank
financial companies supervised by the
Board, designated FMUs, securities
broker-dealers, credit unions, or
insurance companies. Banking
organizations would apply a multiplier
of 1.25 to the correlation factor for
wholesale exposures to regulated
financial institutions with consolidated
assets of greater than or equal to $100
billion.
Several commenters pointed out that
in the proposed formulas for wholesale
exposures to unregulated and regulated
financial institutions, the 0.18
multiplier should be revised to 0.12 in
order to be consistent with Basel III. The
agencies have corrected this aspect of
both formulas in the final rule.
Another comment asserted that the
1.25 multiplier for the correlation factor
for wholesale exposures to unregulated
financial institutions or regulated
financial institutions with more than
$100 billion in assets is an overly blunt
tool and is not necessary as single
counterparty credit limits already
address interconnectivity risk.
Consistent with the concerns about
systemic risk and interconnectedness
surrounding these classes of
institutions, the agencies continue to
believe that the 1.25 multiplier
appropriately reflects the associated
additional risk. Therefore, the final rule
retains the 1.25 multiplier. In addition,
the final rule also adopts the definition
of ‘‘regulated financial institution’’
without change from the proposal. As
discussed in section V.B, above, the
agencies and the FDIC received
significant comment on the definition of
‘‘financial institution’’ in the context of
deductions of investments in the capital
of unconsolidated financial institutions.
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That definition also, under the proposal,
defined the universe of ‘‘unregulated’’
financial institutions as companies
meeting the definition of ‘‘financial
institution’’ that were not regulated
financial institutions. For the reasons
discussed in section V.B of the
preamble, the agencies have modified
the definition of ‘‘financial institution,’’
including by introducing an ownership
interest threshold to the ‘‘predominantly
engaged’’ test to determine if a banking
organization must subject a particular
unconsolidated investment in a
company that may be a financial
institution to the relevant deduction
thresholds under subpart C of the final
rule. While commenters stated that it
would be burdensome to determine
whether an entity falls within the
definition of financial institution using
the predominantly engaged test, the
agencies believe that advanced
approaches banking organizations
should have the systems and resources
to identify the activities of their
wholesale counterparties. Accordingly,
under the final rule, the agencies have
adopted a definition of ‘‘unregulated
financial institution’’ that does not
include the ownership interest
threshold test but otherwise
incorporates revisions to the definition
of ‘‘financial institution.’’ Under the
final rule, an ‘‘unregulated financial
institution’’ is a financial institution
that is not a regulated financial
institution and that meets the definition
of ‘‘financial institution’’ under the final
rule without regard to the ownership
interest thresholds set forth in
paragraph (4)(i) of that definition. The
agencies believe the ‘‘unregulated
financial institution’’ definition is
necessary to maintain an appropriate
scope for the 1.25 multiplier consistent
with the proposal and Basel III.
4. Credit Valuation Adjustments
After the recent financial crisis, the
BCBS reviewed the treatment of
counterparty credit risk and found that
roughly two-thirds of counterparty
credit risk losses during the crisis were
due to fair value losses from CVA (that
is, the fair value adjustment to reflect
counterparty credit risk in the valuation
of an OTC derivative contract), whereas
one-third of counterparty credit risk
losses resulted from actual defaults. The
internal ratings-based approach in Basel
II addressed counterparty credit risk as
a combination of default risk and credit
migration risk. Credit migration risk
accounts for fair value losses resulting
from deterioration of counterparties’
credit quality short of default and is
addressed in Basel II via the maturity
adjustment multiplier. However, the
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maturity adjustment multiplier in Basel
II was calibrated for loan portfolios and
may not be suitable for addressing CVA
risk. Basel III therefore includes an
explicit capital requirement for CVA
risk. Accordingly, consistent with Basel
III and the proposal, the final rule
requires banking organizations to
calculate risk-weighted assets for CVA
risk.
Consistent with the Basel III CVA
capital requirement and the proposal,
the final rule reflects in risk-weighted
assets a potential increase of the firmwide CVA due to changes in
counterparties’ credit spreads, assuming
fixed expected exposure (EE) profiles.
The proposed and final rules provide
two approaches for calculating the CVA
capital requirement: The simple
approach and the advanced CVA
approach. However, unlike Basel III,
they do not include references to credit
ratings.
Consistent with the proposal and
Basel III, the simple CVA approach in
the final rule permits calculation of the
CVA capital requirement (KCVA) based
on a formula described in more detail
below, with a modification consistent
with section 939A of the Dodd-Frank
Act. Under the advanced CVA approach
in the final rule, consistent with the
proposal, a banking organization would
use the VaR model that it uses to
calculate specific risk under section
207(b) of subpart F or another model
that meets the quantitative requirements
of sections 205(b) and 207(b)(1) of
subpart F to calculate its CVA capital
requirement for its entire portfolio of
OTC derivatives that are subject to the
CVA capital requirement 196 by
modeling the impact of changes in the
counterparties’ credit spreads, together
with any recognized CVA hedges on the
CVA for the counterparties. To convert
the CVA capital requirement to a riskweighted asset amount, a banking
organization must multiply its CVA
capital requirement by 12.5. The CVA
risk-weighted asset amount is not a
component of credit risk-weighted
assets and therefore is not subject to the
1.06 multiplier for credit risk-weighted
assets under the final rule. Consistent
with the proposal, the final rule
provides that only a banking
organization that is subject to the market
risk rule and had obtained prior
approval from its primary Federal
196 Certain CDS may be exempt from inclusion in
the portfolio of OTC derivatives that are subject to
the CVA capital requirement. For example, a CDS
on a loan that is recognized as a credit risk mitigant
and receives substitution treatment under section
134 would not be included in the portfolio of OTC
derivatives that are subject to the CVA capital
requirement.
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supervisor to calculate (1) the EAD for
OTC derivative contracts using the IMM
described in section 132, and (2) the
specific risk add-on for debt positions
using a specific risk model described in
section 207(b) of subpart F is eligible to
use the advanced CVA approach. A
banking organization that receives such
approval would be able to continue to
use the advanced CVA approach until it
notifies its primary Federal supervisor
in writing that it expects to begin
calculating its CVA capital requirement
using the simple CVA approach. Such
notice must include an explanation
from the banking organization as to why
it is choosing to use the simple CVA
approach and the date when the
banking organization would begin to
calculate its CVA capital requirement
using the simple CVA approach.
Consistent with the proposal, under
the final rule, when calculating a CVA
capital requirement, a banking
organization may recognize the hedging
benefits of single name CDS, single
name contingent CDS, any other
equivalent hedging instrument that
references the counterparty directly, and
index CDS (CDSind), provided that the
equivalent hedging instrument is
managed as a CVA hedge in accordance
with the banking organization’s hedging
policies. A tranched or nth-to-default
CDS would not qualify as a CVA hedge.
In addition, any position that is
recognized as a CVA hedge would not
be a covered position under the market
risk rule, except in the case where the
banking organization is using the
advanced CVA approach, the hedge is a
CDSind, and the VaR model does not
capture the basis between the spreads of
the index that is used as the hedging
instrument and the hedged counterparty
exposure over various time periods, as
discussed in further detail below. The
agencies and the FDIC received several
comments on the proposed CVA capital
requirement. One commenter asserted
that there was ambiguity in the ‘‘total
CVA risk-weighted assets’’ definition
which could be read as indicating that
KCVA is calculated for each counterparty
and then summed. The agencies agree
that KCVA relates to a banking
organization’s entire portfolio of OTC
derivatives contracts, and the final rule
reflects this clarification.
A commenter asserted that the
proposed CVA treatment should not
apply to central banks, MDBs and other
similar counterparties that have very
low credit risk, such as the Bank for
International Settlements and the
European Central Bank, as well as U.S.
PSEs. Another commenter pointed out
that the proposal in the European Union
to implement Basel III excludes
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62135
sovereign, pension fund, and corporate
counterparties from the proposed CVA
treatment. Another commenter argued
that the proposed CVA treatment should
not apply to transactions executed with
end-users when hedging business risk
because the resulting increase in pricing
will disproportionately impact smalland medium-sized businesses.
The final rule does not exempt the
entities suggested by commenters.
However, the agencies anticipate that a
counterparty that is exempt from the
0.03 percent PD floor under
§ l.131(d)(2) and receives a zero
percent risk weight under § l.32 (that
is, central banks, MDBs, the Bank for
International Settlements and European
Central Bank) likely would attract a
minimal CVA requirement because the
credit spreads associated with these
counterparties have very little
variability. Regarding the other entities
mentioned by commenters (U.S. public
sector entities, pension funds and
corporate end-users), the agencies
believe it is appropriate for CVA to
apply as these counterparty types
exhibit varying degrees of credit risk.
Some commenters asked that the
agencies and the FDIC clarify that
interest rate hedges of CVA are not
covered positions as defined in subpart
F and, therefore, not subject to a market
risk capital requirement. In addition,
some commenters asserted that the
overall capital requirements for CVA are
more appropriately addressed as a
trading book issue in the context of the
BCBS Fundamental Review of the
Trading Book.197 Another commenter
asserted that CVA rates hedges (to the
extent they might be covered positions)
should be excluded from the market-risk
rule capital requirements until
supervisors are ready to approve
allowing CVA rates sensitivities to be
incorporated into a banking
organization’s general market risk VaR.
The agencies recognize that CVA is
not a covered position under the market
risk rule. Hence, as elaborated in the
market risk rule, hedges of non-covered
positions that are not themselves trading
positions also are not eligible to be a
covered position under the market risk
rule. Therefore, the agencies clarify that
non-credit risk hedges (market risk
hedges or exposure hedges) of CVA
generally are not covered positions
under the market risk rule, but rather
are assigned risk-weighted asset
amounts under subparts D and E of the
197 See ‘‘Fundamental review of the trading book’’
(May 2012) available at https://www.bis.org/publ/
bcbs219.pdf.
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final rule.198 Once the BCBS
Fundamental Review of the Trading
Book is complete, the agencies will
review the BCBS findings and consider
whether they are appropriate for U.S.
banking organizations.
One commenter asserted that
observable LGDs for credit derivatives
do not represent the best estimation of
LGD for calculating CVA under the
advanced CVA approach, and that the
final rule should instead consider a
number of parameters, including market
observable recovery rates on unsecured
bonds and structural components of the
derivative. Another commenter argued
that banking organizations should be
permitted greater flexibility in
determining market-implied loss given
default (LGDMKT) and credit spread
factors for VaR.
Consistent with the BCBS’s frequently
asked question (BCBS FAQ) on this
topic,199 the agencies recognize that
while there is often limited market
information of LGDMKT (or equivalently
the market implied recovery rate), the
agencies consider the use of LGDMKT to
be the most appropriate approach to
quantify CVA. It is also the market
convention to use a fixed recovery rate
for CDS pricing purposes; banking
organizations may use that information
for purposes of the CVA capital
requirement in the absence of other
information. In cases where a netting set
of OTC derivative contracts has a
different seniority than those derivative
contracts that trade in the market from
which LGDMKT is inferred, a banking
organization may adjust LGDMKT to
reflect this difference in seniority.
Where no market information is
available to determine LGDMKT, a
banking organization may propose a
method for determining LGDMKT based
upon data collected by the banking
organization that would be subject to
approval by its primary Federal
supervisor. The final rule has been
amended to include this alternative.
Regarding the proposed CVA EAD
calculation assumptions in the
advanced CVA approach, one
commenter asserted that EE constant
treatment is inappropriate, and that it is
more appropriate to use the weighted
average maturity of the portfolio rather
than the netting set. Another commenter
asserted that maturity should equal the
weighted average maturity of all
transactions in the netting set, rather
than the greater of the notional weighted
average maturity and the maximum of
half of the longest maturity occurring in
the netting set. The agencies note that
this issue is relevant only where a
banking organization utilized the
current exposure method or the
‘‘shortcut’’ method, rather than IMM, for
any immaterial portfolios of OTC
derivatives contracts. As a result, the
final rule retains the requirement to use
the greater of the notional weighted
average maturity (WAM) and the
maximum of half of the longest maturity
in the netting set when calculating EE
constant treatment in the advanced CVA
approach.
One commenter asked the agencies
and the FDIC to clarify that section
132(c)(3) would exempt the purchased
CDS from the proposed CVA capital
requirements in section 132(e) of the
final rule. Consistent with the BCBS
FAQ on this topic, the agencies agree
that purchased credit derivative
protection against a wholesale exposure
that is subject to the double default
framework or the PD substitution
approach and where the wholesale
exposure itself is not subject to the CVA
capital requirement, will not be subject
to the CVA capital requirement in the
final rule. Also consistent with the
BCBS FAQ, the purchased credit
derivative protection may not be
recognized as a hedge for any other
exposure under the final rule.
Another commenter asserted that
single-name proxy CDS trades should be
allowed as hedges in the advanced CVA
approach CVA VaR calculation. Under
the final rule, a banking organization is
permitted to recognize the hedging
benefits of single name CDS, single
name contingent CDS, any other
equivalent hedging instrument that
references the counterparty directly, and
CDSind, provided that the hedging
instrument is managed as a CVA hedge
in accordance with the banking
organization’s hedging policies. The
final rule does not permit the use of
single-name proxy CDS. The agencies
believe this is an important limitation
because of the significant basis risk that
could arise from the use of a singlename proxy.
Additionally, the final rule reflects
several clarifying amendments to the
proposed rule. First, the final rule
divides the Advanced CVA formulas in
the proposed rule into two parts:
Formula 3 and Formula 3a. The
agencies believe that this clarification is
important to reflect the different
purposes of the two formulas: The first
formula (Formula 3) is for the CVA VaR
calculation, whereas the second formula
(Formula 3a) is for calculating CVA for
each credit spread simulation scenario.
The final rule includes a description
that clarifies each formula’s purpose. In
addition, the notations in proposed
Formula 3 have been changed from
CVAstressedVaR and CVAunstressedVaR to
VaRCVAstressed and VaRCVAunstressed. The
definitions of these terms have not
changed in the final rule. Finally, the
subscript ‘‘j’’ in Formula 3a has been
defined as referring either to stressed or
unstressed calibrations. These formulas
are discussed in the final rule
description below.
198 The agencies believe that a banking
organization needs to demonstrate rigorous risk
management and the efficacy of its CVA hedges and
should follow the risk management principles of
the Interagency Supervisory Guidance on
Counterparty Credit Risk Management (2011) and
identification of covered positions as in the
agencies’ market risk rule, see 77 FR 53060 (August
30, 2012).
199 See ‘‘Basel III counterparty credit risk and
exposures to central counterparties—Frequently
asked questions (December 2012 (update of FAQs
published November 2012)) at https://www.bis.org/
publ/bcbs237.pdf.
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a. Simple Credit Valuation Adjustment
Approach
Under the final rule, a banking
organization without approval to use the
advanced CVA approach must use
formula 1 to calculate its CVA capital
requirement for its entire portfolio of
OTC derivative contracts. The simple
CVA approach is based on an analytical
approximation derived from a general
CVA VaR formulation under a set of
simplifying assumptions:
(1) All credit spreads have a flat term
structure;
(2) All credit spreads at the time
horizon have a lognormal distribution;
(3) Each single name credit spread is
driven by the combination of a single
systematic factor and an idiosyncratic
factor;
(4) The correlation between any single
name credit spread and the systematic
factor is equal to 0.5;
(5) All credit indices are driven by the
single systematic factor; and
(6) The time horizon is short (the
square root of time scaling to 1 year is
applied). The approximation is based on
the linearization of the dependence of
both CVA and CDS hedges on credit
spreads. Given the assumptions listed
above, a measure of CVA VaR has a
closed-form analytical solution. The
formula of the simple CVA approach is
obtained by applying certain
standardizations, conservative
adjustments, and scaling to the
analytical CVA VaR result.
A banking organization calculates
KCVA, where:
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Internal PD
(in percent)
Weight wi
(in percent)
0.00–0.07 ..........................
>0.07–0.15 ........................
>0.15–0.40 ........................
>0.4–2.00 ..........................
>2.0–6.00 ..........................
>6.0 ...................................
0.70
0.80
1.00
2.00
3.00
10.00
described in section 132(c) of the final
rule, as adjusted by Formula 2 or the
IMM described in section 132(d) of the
final rule. When the banking
organization calculates EAD using the
IMM, EADitotal equals EADunstressed.
EADitotal in Formula 1 refers to the
sum of the EAD for all netting sets of
for hedging, a banking organization is
allowed to treat the notional amount in
an index attributable to that
counterparty as a single name hedge of
counterparty i (Bi,) when calculating
KCVA and subtract the notional amount
of Bi from the notional amount of the
CDSind. The CDSind hedge with the
notional amount reduced by Bi can still
be treated as a CVA index hedge.
b. Advanced Credit Valuation
Adjustment Approach
The final rule requires that the VaR
model incorporate only changes in the
counterparties’ credit spreads, not
changes in other risk factors; it does not
require a banking organization to
capture jump-to-default risk in its VaR
model.
In order for a banking organization to
receive approval to use the advanced
CVA approach under the final rule, the
banking organization needs to have the
systems capability to calculate the CVA
capital requirement on a daily basis but
is not expected or required to calculate
the CVA capital requirement on a daily
basis.
The CVA capital requirement under
the advanced CVA approach is equal to
the general market risk capital
requirement of the CVA exposure using
the ten-business-day time horizon of the
market risk rule. The capital
requirement does not include the
incremental risk requirement of subpart
F. If a banking organization uses the
current exposure methodology to
calculate the EAD of any immaterial
OTC derivative portfolio, under the final
rule the banking organization must use
this EAD as a constant EE in the formula
for the calculation of CVA. Also, the
banking organization must set the
maturity equal to the greater of half of
the longest maturity occurring in the
netting set and the notional weighted
average maturity of all transactions in
the netting set.
200 These weights represent the assumed values of
the product of a counterparties’ current credit
spread and the volatility of that credit spread.
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The term ‘‘exp’’ is the exponential
function. Quantity Mi in Formulas 1 and
2 refers to the EAD-weighted average of
the effective maturity of each netting set
with counterparty i (where each netting
set’s M cannot be smaller than one).
Quantity Mihedge in Formula 1 refers to
the notional weighted average maturity
of the hedge instrument. Quantity Mind
in Formula 1 equals the maturity of the
CDSind or the notional weighted average
maturity of any CDSind purchased to
hedge CVA risk of counterparty i.
Quantity Bi in Formula 1 refers to the
sum of the notional amounts of any
purchased single name CDS referencing
counterparty i that is used to hedge CVA
risk to counterparty i multiplied by (1exp(¥0.05 × Mi hedge))/(0.05 × Mihedge).
Quantity B ind in Formula 1 refers to the
notional amount of one or more CDSind
purchased as protection to hedge CVA
risk for counterparty i multiplied by (1exp(¥0.05 × Mind))/(0.05 × Mind). If
counterparty i is part of an index used
OTC derivative contracts with
TABLE 26—ASSIGNMENT OF
COUNTERPARTY WEIGHT UNDER THE counterparty i calculated using the
current exposure methodology
SIMPLE CVA
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In Formula 1, wi refers to the weight
applicable to counterparty i assigned
according to Table 26 below.200 In Basel
III, the BCBS assigned wi based on the
external rating of the counterparty.
However, consistent with the proposal
and section 939A of the Dodd-Frank
Act, the final rule assigns wi based on
the relevant PD of the counterparty, as
assigned by the banking organization.
Quantity wind in Formula 1 refers to the
weight applicable to the CDSind based on
the average weight under Table 26 of the
underlying reference names that
comprise the index.
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advanced CVA approach to calculate
KCVA as follows:
VaRJ is the 99 percent VaR reflecting
changes of CVAj and fair value of
eligible hedges (aggregated across all
counterparties and eligible hedges)
resulting from simulated changes of
credit spreads over a ten-day time
publicly traded debt instrument of the
counterparty, or, where a publicly traded
debt instrument spread is not available, a
proxy spread based on the credit quality,
industry and region of the counterparty.
(E) EEi = the sum of the expected exposures
for all netting sets with the counterparty at
revaluation time ti calculated using the IMM.
(F) Di = the risk-free discount factor at time
ti, where D0 = 1.
(G) The function exp is the exponential
function.
(H) The subscript j refers either to a
stressed or an unstressed calibration as
201 For purposes of this formula, the subscript ‘‘ ’’
j
refers either to a stressed or unstressed calibration
as described in section 133(e)(6)(iv) and (v) of the
final rule.
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In Formula 3a:
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described in section 132(e)(6)(iv) and (v) of
the final rule.
Under the final rule, if a banking
organization’s VaR model is not based
on full repricing, the banking
organization must use either Formula 4
or Formula 5 to calculate credit spread
sensitivities. If the VaR model is based
on credit spread sensitivities for specific
tenors, the banking organization must
calculate each credit spread sensitivity
according to Formula 4:
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ER11OC13.011
(A) ti = the time of the i-th revaluation time
bucket starting from t0 = 0.
(B) tT = the longest contractual maturity
across the OTC derivative contracts with the
counterparty.
(C) si = the CDS spread for the counterparty
at tenor ti used to calculate the CVA for the
counterparty. If a CDS spread is not available,
the banking organization must use a proxy
spread based on the credit quality, industry
and region of the counterparty.
(D) LGDMKT = the loss given default of the
counterparty based on the spread of a
horizon.201 CVAj for a given
counterparty must be calculated
according to
11OCR2
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The final rule requires a banking
organization to use the formula for the
Under the final rule, a banking
organization must calculate
VaRCVAunstressed using CVAUnstressed and
VaRCVAstressed using CVAStressed. To
calculate the CVAUnstressed measure in
Formula 3a, a banking organization
must use the EE for a counterparty
calculated using current market data to
compute current exposures and estimate
model parameters using the historical
observation period required under
section 205(b)(2) of subpart F. However,
if a banking organization uses the
‘‘shortcut’’ method described in section
132(d)(5) of the final rule to capture the
effect of a collateral agreement when
estimating EAD using the IMM, the
banking organization must calculate the
EE for the counterparty using that
method and keep that EE constant with
the maturity equal to the maximum of
half of the longest maturity occurring in
the netting set, and the notional
weighted average maturity of all
transactions in the netting set.
To calculate the CVAStressed measure in
Formula 3a, the final rule requires a
banking organization to use the EE for
a counterparty calculated using the
stress calibration of the IMM. However,
if a banking organization uses the
‘‘shortcut’’ method described in section
132(d)(5) of the final rule to capture the
effect of a collateral agreement when
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estimating EAD using the IMM, the
banking organization must calculate the
EE for the counterparty using that
method and keep that EE constant with
the maturity equal to the greater of half
of the longest maturity occurring in the
netting set with the notional amount
equal to the weighted average maturity
of all transactions in the netting set.
Consistent with Basel III, the final rule
requires a banking organization to
calibrate the VaR model inputs to
historical data from the most severe
twelve-month stress period contained
within the three-year stress period used
to calculate EE. However, the agencies
retain the flexibility to require a banking
organization to use a different period of
significant financial stress in the
calculation of the CVAStressed measure
that better reflects actual historic losses
of the portfolio.
Under the final rule, a banking
organization’s VaR model is required to
capture the basis between the spreads of
the index that is used as the hedging
instrument and the hedged counterparty
exposure over various time periods,
including benign and stressed
environments. If the VaR model does
not capture that basis, the banking
organization is permitted to reflect only
50 percent of the notional amount of the
CDSind hedge in the VaR model.
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62139
5. Cleared Transactions (Central
Counterparties)
As discussed more fully in section
VIII.E of this preamble on cleared
transactions under the standardized
approach, CCPs help improve the safety
and soundness of the derivatives and
repo-style transaction markets through
the multilateral netting of exposures,
establishment and enforcement of
collateral requirements, and market
transparency. Similar to the changes to
the cleared transaction treatment in the
subpart D of the final rule, the
requirements regarding the cleared
transaction framework in the subpart E
has been revised to reflect the material
changes from the BCBS CCP interim
framework. Key changes from the CCP
interim framework, include: (1)
Allowing a clearing member banking
organization to use a reduced margin
period of risk when using the IMM or
a scaling factor of no less than 0.71 202
when using the CEM in the calculation
of its EAD for client-facing derivative
trades; (2) updating the risk weights
applicable to a clearing member banking
organization’s exposures when the
202 See Table 20 in section VIII.E of this preamble.
Consistent with the scaling factor for the CEM in
Table 20, an advanced approaches banking
organization may reduce the margin period of risk
when using the IMM to no shorter than 5 days.
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clearing member banking organization
guarantees QCCP performance; (3)
permitting clearing member banking
organizations to choose from one of two
approaches for determining the capital
requirement for exposures to default
fund contributions; and (4) updating the
CEM formula to recognize netting to a
greater extent for purposes of
calculating its risk-weighted asset
amount for default fund contributions.
Additionally, changes in response to
comments received on the proposal, as
discussed in detail in section VIII.E of
this preamble with respect to cleared
transactions in the standardized
approach, are also reflected in the final
rule for advanced approaches. Banking
organizations seeking more information
on the changes relating to the material
elements of the BCBS CCP interim
framework and the comments received
should refer to section VIII.E of this
preamble.
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6. Stress Period for Own Estimates
During the recent financial crisis,
increased volatility in the value of
collateral led to higher counterparty
exposures than estimated by banking
organizations. Under the collateral
haircut approach in the advanced
approaches final rule, consistent with
the proposal, a banking organization
that receives prior approval from its
primary Federal supervisor may
calculate market price and foreign
exchange volatility using own internal
estimates. In response to the increased
volatility experienced during the crisis,
however, the final rule modifies the
quantitative standards for approval by
requiring banking organizations to base
own internal estimates of haircuts on a
historical observation period that
reflects a continuous 12-month period
of significant financial stress
appropriate to the security or category of
securities. As described in section VIII.F
of this preamble with respect to the
standardized approach, a banking
organization is also required to have
policies and procedures that describe
how it determines the period of
significant financial stress used to
calculate the banking organization’s
own internal estimates, and must be
able to provide empirical support for the
period used. To ensure an appropriate
level of conservativeness, in certain
circumstances a primary Federal
supervisor may require a banking
organization to use a different period of
significant financial stress in the
calculation of own internal estimates for
haircuts. The agencies are adopting this
aspect of the proposal without change.
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B. Removal of Credit Ratings
1. Eligible Guarantor
Consistent with the proposed rule and
section 939A of the Dodd-Frank Act, the
final rule includes a number of changes
to definitions in the advanced
approaches rule that currently reference
credit ratings.203 These changes are
consistent with the alternative standards
included in the Standardized Approach
and alternative standards that already
have been implemented in the agencies’
market risk rule. In addition, the final
rule includes necessary changes to the
hierarchy for risk weighting
securitization exposures necessitated by
the removal of the ratings-based
approach, as described further below.
In certain instances, the final rule
uses an ‘‘investment grade’’ standard
that does not rely on credit ratings.
Under the final rule and consistent with
the market risk rule, investment grade
means that the entity to which the
banking organization is exposed through
a loan or security, or the reference entity
with respect to a credit derivative, has
adequate capacity to meet financial
commitments for the projected life of
the asset or exposure. Such an entity or
reference entity has adequate capacity to
meet financial commitments if the risk
of its default is low and the full and
timely repayment of principal and
interest is expected.
The agencies are largely adopting the
proposed alternatives to ratings as
proposed. Consistent with the proposal,
the agencies are retaining the standards
used to calculate the PFE for derivative
contracts (as set forth in Table 2 of the
final rule), which are based in part on
whether the counterparty satisfies the
definition of investment grade under the
final rule. The agencies are also
adopting as proposed the term ‘‘eligible
double default guarantor,’’ which is
used for purposes of determining
whether a banking organization may
recognize a guarantee or credit
derivative under the credit risk
mitigation framework. In addition, the
agencies are adopting the proposed
requirements for qualifying operational
risk mitigants, which among other
criteria, must be provided by an
unaffiliated company that the banking
organization deems to have strong
capacity to meet its claims payment
obligations and the obligor rating
category to which the banking
organization assigns the company is
assigned a PD equal to or less than 10
basis points.
Previously, to be an eligible
securitization guarantor under the
advanced approaches rule, a guarantor
was required to meet a number of
criteria. For example, the guarantor
must have issued and outstanding an
unsecured long-term debt security
without credit enhancement that has a
long-term applicable external rating in
one of the three highest investmentgrade rating categories. The final rule
replaces the term ‘‘eligible securitization
guarantor’’ with the term ‘‘eligible
guarantor,’’ which includes certain
entities that have issued and
outstanding unsecured debt securities
without credit enhancement that are
investment grade. Comments and
modifications to the definition of
eligible guarantor are discussed below
and in section VIII.F of this preamble.
203 See
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2. Money Market Fund Approach
Previously, under the money market
fund approach in the advanced
approaches rule, banking organizations
were permitted to assign a 7 percent risk
weight to exposures to money market
funds that were subject to SEC rule 2a–
7 and that had an applicable external
rating in the highest investment grade
rating category. The proposed rule
eliminated the money market fund
approach. Commenters stated that the
elimination of the existing 7 percent risk
weight for equity exposures to money
market funds would result in an overly
stringent treatment for those exposures
under the remaining look-through
approaches. However, during the recent
financial crisis, several money market
funds demonstrated elevated credit risk
that is not consistent with a low 7
percent risk weight. Accordingly, the
agencies believe it is appropriate to
eliminate the preferential risk weight for
money market fund investments. As a
result of the changes, a banking
organization must use one of the three
alternative approaches under section
154 of the final rule to determine the
risk weight for its exposures to a money
market fund.
3. Modified Look-Through Approaches
for Equity Exposures to Investment
Funds
Under the proposal, risk weights for
equity exposures under the simple
modified look-through approach would
have been based on the highest risk
weight assigned to the exposure under
the standardized approach (subpart D)
based on the investment limits in the
fund’s prospectus, partnership
agreement, or similar contract that
defines the fund’s permissible
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investments. As discussed in the
preamble regarding the standardized
approach, commenters expressed
concerns regarding their ability to
implement the look-through approaches
for investment funds that hold
securitization exposures. However, the
agencies believe that banking
organizations should be aware of the
nature of the investments in a fund in
which the organization invests. To the
extent that information is not available,
the treatment in the final rule will create
incentives for banking organizations to
obtain the information necessary to
compute risk-based capital requirements
under the approach. These incentives
are consistent with the agencies’
supervisory aim that banking
organizations have sufficient
understanding of the characteristics and
risks of their investments.
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C. Revisions to the Treatment of
Securitization Exposures
1. Definitions
As discussed in section VIII.H of this
preamble with respect to the
standardized approach, the proposal
introduced a new definition for
resecuritization exposures consistent
with the 2009 Enhancements and
broadened the definition of a
securitization exposure. In addition, the
agencies and the FDIC proposed to
amend the existing definition of
traditional securitization in order to
exclude certain types of investment
firms from treatment under the
securitization framework. Consistent
with the approach taken with respect to
the standardized approach, the
proposed definitions under the
securitization framework in the
advanced approach are largely finalized
as proposed, except for changes
described below. Banking organizations
should refer to part VIII.H of this
preamble for further discussion of these
comments.
In response to the proposed definition
of traditional securitization,
commenters generally agreed with the
proposed exemptions from the
definition and requested that the
agencies and the FDIC provide
exemptions for exposures to a broader
set of investment firms, such as pension
funds operated by state and local
governments. In view of the comments
regarding pension funds, the final rule,
as described in part VIII.H of this
preamble, excludes from the definition
of traditional securitization a
‘‘governmental plan’’ (as defined in 29
U.S.C. 1002(32)) that complies with the
tax deferral qualification requirements
provided in the Internal Revenue Code.
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In response to the proposed definition
of resecuritization, commenters
requested clarification regarding its
potential scope of application to
exposures that they believed should not
be considered resecuritizations. In
response, the agencies have amended
the definition of resecuritization by
excluding securitizations that feature retranching of a single exposure. In
addition, the agencies note that for
purposes of the final rule, a
resecuritization does not include passthrough securities that have been pooled
together and effectively re-issued as
tranched securities. This is because the
pass-through securities do not tranche
credit protection and, as a result, are not
considered securitization exposures
under the final rule.
Previously, under the advanced
approaches rule issued in 2007, the
definition of eligible securitization
guarantor included, among other
entities, any entity (other than a
securitization SPE) that has issued and
has outstanding an unsecured long-term
debt security without credit
enhancement that has a long-term
applicable external rating in one of the
three highest investment-grade rating
categories, or has a PD assigned by the
banking organization that is lower than
or equal to the PD associated with a
long-term external rating in the third
highest investment-grade category. The
final rule removes the existing
references to ratings from the definition
of an eligible guarantor (the new term
for an eligible securitization guarantor)
and finalizes the requirements as
proposed, as described in section VIII.F
of this preamble.
During the recent financial crisis,
certain guarantors of securitization
exposures had difficulty honoring those
guarantees as the financial condition of
the guarantors deteriorated at the same
time as the guaranteed exposures
experienced losses. Consistent with the
proposal, a guarantor is not an eligible
guarantor under the final rule if the
guarantor’s creditworthiness is
positively correlated with the credit risk
of the exposures for which it has
provided guarantees. In addition,
insurance companies engaged
predominately in the business of
providing credit protection are not
eligible guarantors. Further discussion
can be found in section VIII.F of this
preamble.
2. Operational Criteria for Recognizing
Risk Transference in Traditional
Securitizations
The proposal outlined certain
operational requirements for traditional
securitizations that had to be met in
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order to apply the securitization
framework. Consistent with the
standardized approach as discussed in
section VIII.H of this preamble, the
agencies are adopting the operational
criteria for recognizing risk transference
in traditional securitizations largely as
proposed.
3. The Hierarchy of Approaches
Consistent with section 939A of the
Dodd-Frank Act, the proposed rule
removed the ratings-based approach
(RBA) and internal assessment approach
for securitization exposures. The
agencies are adopting the hierarchy
largely as proposed. Under the final
rule, the hierarchy for securitization
exposures is as follows:
(1) A banking organization is required
to deduct from common equity tier 1
capital any after-tax gain-on-sale
resulting from a securitization and
apply a 1,250 percent risk weight to the
portion of a CEIO that does not
constitute after-tax gain-on-sale.
(2) If a securitization exposure does
not require deduction, a banking
organization is required to assign a risk
weight to the securitization exposure
using the SFA. The agencies expect
banking organizations to use the SFA
rather than the SSFA in all instances
where data to calculate the SFA is
available.
(3) If the banking organization cannot
apply the SFA because not all the
relevant qualification criteria are met, it
is allowed to apply the SSFA. A banking
organization should be able to explain
and justify (for example, based on data
availability) to its primary Federal
supervisor any instances in which the
banking organization uses the SSFA
rather than the SFA for its securitization
exposures.
The SSFA, described in detail in part
VIII.H of this preamble, is similar in
construct and function to the SFA. A
banking organization needs several
inputs to calculate the SSFA. The first
input is the weighted-average capital
requirement calculated under the
standardized approach that applies to
the underlying exposures as if they are
held directly by the banking
organization. The second and third
inputs indicate the position’s level of
subordination and relative size within
the securitization. The fourth input is
the level of delinquencies experienced
on the underlying exposures. A banking
organization must apply the hierarchy
of approaches in section 142 of this final
rule to determine which approach it
applies to a securitization exposure. The
SSFA has been finalized as proposed,
with the exception of some
modifications to the delinquency
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parameter, as discussed in part VIII.H of
this preamble.
4. Guarantees and Credit Derivatives
Referencing a Securitization Exposure
The current advanced approaches rule
includes methods for calculating riskweighted assets for nth-to-default credit
derivatives, including first-to-default
credit derivatives and second-orsubsequent-to-default credit
derivatives.204 The current advanced
approaches rule, however, does not
specify how to treat guarantees or credit
derivatives (other than nth-to-default
credit derivatives) purchased or sold
that reference a securitization exposure.
Accordingly, the proposal included
specific treatment for credit protection
purchased or provided in the form of a
guarantee or credit derivative (other
than an nth-to-default credit derivative)
that references a securitization
exposure.
For a guarantee or credit derivative
(other than an nth-to-default credit
derivative) where the banking
organization has provided protection,
the final rule requires a banking
organization providing credit protection
to determine the risk-based capital
requirement for the guarantee or credit
derivative as if it directly holds the
portion of the reference exposure
covered by the guarantee or credit
derivative. The banking organization
calculates its risk-based capital
requirement for the guarantee or credit
derivative by applying either (1) the
SFA as provided in section 143 of the
final rule to the reference exposure if
the banking organization and the
reference exposure qualify for the SFA;
or (2) the SSFA as provided in section
144 of the final rule. If the guarantee or
credit derivative and the reference
securitization exposure do not qualify
for the SFA, or the SSFA, the banking
organization is required to assign a
1,250 percent risk weight to the notional
amount of protection provided under
the guarantee or credit derivative.
The final rule also clarifies how a
banking organization may recognize a
guarantee or credit derivative (other
than an nth-to-default credit derivative)
purchased as a credit risk mitigant for
a securitization exposure held by the
banking organization. A banking
organization that purchases an OTC
credit derivative (other than an nth-to204 Nth-to-default credit derivative means a credit
derivative that provides credit protection only for
the nth-defaulting reference exposure in a group of
reference exposures. See 12 CFR part 3, appendix
C, section 42(l) (national banks) and 12 CFR part
167, appendix C, section 42(l) (Federal savings
associations) (OCC); 12 CFR part 208, appendix F,
and 12 CFR part 225, appendix G (Board).
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default credit derivative) that is
recognized as a credit risk mitigant for
a securitization exposure that is not a
covered position under the market risk
rule is not required to compute a
separate counterparty credit risk capital
requirement provided that the banking
organization does so consistently for all
such credit derivatives. The banking
organization must either include all or
exclude all such credit derivatives that
are subject to a qualifying master netting
agreement from any measure used to
determine counterparty credit risk
exposure to all relevant counterparties
for risk-based capital purposes. If a
banking organization cannot, or chooses
not to, recognize a credit derivative that
is a securitization exposure as a credit
risk mitigant, the bank must determine
the exposure amount of the credit
derivative under the treatment for OTC
derivatives in section 132. If the banking
organization purchases the credit
protection from a counterparty that is a
securitization, the banking must
determine the risk weight for
counterparty credit risk according to the
securitization framework. If the banking
organization purchases credit protection
from a counterparty that is not a
securitization, the banking organization
must determine the risk weight for
counterparty credit risk according to
general risk weights under section 131.
5. Due Diligence Requirements for
Securitization Exposures
As the recent financial crisis
unfolded, weaknesses in exposures
underlying securitizations became
apparent and resulted in NRSROs
downgrading many securitization
exposures held by banking
organizations. The agencies found that
many banking organizations relied on
NRSRO ratings as a proxy for the credit
quality of securitization exposures they
purchased and held without conducting
their own sufficient independent credit
analysis. As a result, some banking
organizations did not have sufficient
capital to absorb the losses attributable
to these exposures. Accordingly,
consistent with the 2009 Enhancements,
the proposed rule introduced due
diligence requirements that banking
organizations would be required to
undertake to use the SFA or SSFA.
Comments received regarding the
proposed due diligence requirements
and the rationale for adopting the
proposed treatment in the final rule are
discussed in part VIII of the preamble.
6. Nth-to-Default Credit Derivatives
Consistent with the proposal, the final
rule provides that a banking
organization that provides credit
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protection through an nth-to-default
derivative must assign a risk weight to
the derivative using the SFA or the
SSFA. In the case of credit protection
sold, a banking organization must
determine its exposure in the nth-todefault credit derivative as the largest
notional dollar amount of all the
underlying exposures.
When applying the SSFA to
protection provided in the form of an
nth-to-default credit derivative, the
attachment point (parameter A) is the
ratio of the sum of the notional amounts
of all underlying exposures that are
subordinated to the banking
organization’s exposure to the total
notional amount of all underlying
exposures. For purposes of applying the
SFA, parameter A is set equal to the
credit enhancement level (L) used in the
SFA formula. In the case of a first-todefault credit derivative, there are no
underlying exposures that are
subordinated to the banking
organization’s exposure. In the case of a
second-or-subsequent-to default credit
derivative, the smallest (n-1) underlying
exposure(s) are subordinated to the
banking organization’s exposure.
Under the SSFA, the detachment
point (parameter D) is the sum of the
attachment point and the ratio of the
notional amount of the banking
organization’s exposure to the total
notional amount of the underlying
exposures. Under the SFA, Parameter D
is set to equal L plus the thickness of the
tranche (T) under the SFA formula. A
banking organization that does not use
the SFA or SSFA to calculate a risk
weight for an nth-to-default credit
derivative must assign a risk weight of
1,250 percent to the exposure.
For the treatment of protection
purchased through a first-to-default
credit derivative, a banking organization
must determine its risk-based capital
requirement for the underlying
exposures as if the banking organization
had synthetically securitized the
underlying exposure with the lowest
risk-based capital requirement and had
obtained no credit risk mitigant on the
other underlying exposures. A banking
organization must calculate a risk-based
capital requirement for counterparty
credit risk according to section 132 of
the final rule for a first-to-default credit
derivative that does not meet the rules
of recognition for guarantees and credit
derivatives under section 134(b).
For second-or-subsequent-to default
credit derivatives, a banking
organization that obtains credit
protection on a group of underlying
exposures through a nth-to-default credit
derivative that meets the rules of
recognition of section 134(b) of the final
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rule (other than a first-to-default credit
derivative) is permitted to recognize the
credit risk mitigation benefits of the
derivative only if the banking
organization also has obtained credit
protection on the same underlying
exposures in the form of first-through(n-1)-to-default credit derivatives; or if
n-1 of the underlying exposures have
already defaulted. If a banking
organization satisfies these
requirements, the banking organization
determines its risk-based capital
requirement for the underlying
exposures as if the banking organization
had only synthetically securitized the
underlying exposure with the nth
smallest risk-based capital requirement
and had obtained no credit risk mitigant
on the other underlying exposures. A
banking organization that does not
fulfill these requirements must calculate
a risk-based capital requirement for
counterparty credit risk according to
section 132 of the final rule for a nth-todefault credit derivative that does not
meet the rules of recognition of section
134(b) of the final rule.
D. Treatment of Exposures Subject to
Deduction
Under the current advanced
approaches rule, a banking organization
is required to deduct certain exposures
from total capital, including
securitization exposures such as CEIOs,
low-rated securitization exposures, and
high-risk securitization exposures
subject to the SFA; eligible credit
reserves shortfall; and certain failed
capital markets transactions. Consistent
with Basel III, the proposed rule
required a banking organization to
assign a 1,250 percent risk weight to
many exposures that previously were
deducted from capital, except for
deductions from total capital of
insurance underwriting subsidiaries of
BHCs.
In the proposal, the agencies and the
FDIC noted that such treatment would
not be equivalent to a deduction from
tier 1 capital, as the effect of a 1,250
percent risk weight would depend on an
individual banking organization’s
current risk-based capital ratios.
Specifically, when a risk-based capital
ratio (either tier 1 or total risk-based
capital) exceeds 8.0 percent, the effect
on that risk-based capital ratio of
assigning an exposure a 1,250 percent
risk weight would be more conservative
than a deduction from total capital. The
more a risk-based capital ratio exceeds
8.0 percent, the harsher is the effect of
a 1,250 percent risk weight on riskbased capital ratios. Commenters
acknowledged these points and asked
the agencies and the FDIC to replace the
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1,250 percent risk weight with the
maximum risk weight that would
correspond with deduction.
Commenters also stated that the
agencies and the FDIC should consider
the effect of the 1,250 percent risk
weight given that the Basel III proposals,
over time, would require banking
organizations to maintain a total riskbased capital ratio of at least 10.5
percent to meet the minimum required
capital ratio plus the capital
conservation buffer.
The agencies are adopting the
requirements as proposed, in order to
provide for comparability in riskweighted asset measurements across
institutions. The agencies and the FDIC
did not propose to apply a 1,250 percent
risk weight to those exposures currently
deducted from tier 1 capital under the
advanced approaches rule. For example,
the agencies and the FDIC proposed that
an after-tax gain-on-sale that is deducted
from tier 1 under the advanced
approaches rule be deducted from
common equity tier 1 under the
proposed rule. In this regard, the
agencies and the FDIC also clarified that
any asset deducted from common equity
tier 1, tier 1, or tier 2 capital under the
advanced approaches rule would not be
included in the measure of riskweighted assets under the advanced
approaches rule. The agencies have
finalized these requirements as
proposed.
E. Technical Amendments to the
Advanced Approaches Rule
In the proposed rule, the agencies and
the FDIC introduced a number of
amendments to the advanced
approaches rule that were designed to
refine and clarify certain aspects of the
rule’s implementation. The agencies are
adopting each of these technical
amendments as proposed. Additionally,
in the final rule, the agencies are
amending the treatment of defaulted
exposures that are covered by
government guarantees. Each of these
revisions is described below.
1. Eligible Guarantees and Contingent
U.S. Government Guarantees
In order to be recognized as an
eligible guarantee under the advanced
approaches rule, the guarantee, among
other criteria, must be unconditional.
The agencies note that this definition
would exclude certain guarantees
provided by the U.S. Government or its
agencies that would require some action
on the part of the banking organization
or some other third party. However,
based on their risk characteristics, the
agencies believe that these guarantees
should be recognized as eligible
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62143
guarantees. Therefore, the agencies are
amending the definition of eligible
guarantee so that it explicitly includes
a contingent obligation of the U.S.
Government or an agency of the U.S.
Government, the validity of which is
dependent on some affirmative action
on the part of the beneficiary or a third
party (for example, servicing
requirements) irrespective of whether
such contingent obligation is otherwise
considered a conditional guarantee.
Related to the change to the eligible
guarantee definition, the agencies have
amended the provision in the advanced
approaches rule pertaining to the 10
percent floor on the LGD for residential
mortgage exposures. Currently, the rule
provides that the LGD for each segment
of residential mortgage exposures (other
than segments of residential mortgage
exposures for which all or substantially
all of the principal of each exposure is
directly and unconditionally guaranteed
by the full faith and credit of a sovereign
entity) may not be less than 10 percent.
The provision would therefore require a
10 percent LGD floor on segments of
residential mortgage exposures for
which all or substantially of the
principal are conditionally guaranteed
by the U.S. government. The agencies
have amended the final rule to allow an
exception from the 10 percent floor in
such cases.
2. Calculation of Foreign Exposures for
Applicability of the Advanced
Approaches—Insurance Underwriting
Subsidiaries
A banking organization is subject to
the advanced approaches rule if it has
consolidated assets greater than or equal
to $250 billion, or if it has total
consolidated on-balance sheet foreign
exposures of at least $10 billion.205 For
bank holding companies, in particular,
the advanced approaches rule provides
that the $250 billion threshold criterion
excludes assets held by an insurance
underwriting subsidiary. However, a
similar provision does not exist for the
$10 billion foreign-exposure threshold
criterion. Therefore, for bank holding
companies and covered SLHCs, the
Board is excluding assets held by
insurance underwriting subsidiaries
from the $10 billion in total foreign
exposures threshold. The Board believes
such a parallel provision results in a
more appropriate scope of application
for the advanced approaches rule.
205 See 12 CFR part 3, appendix C (national
banks) and 12 CFR part 167, appendix C (Federal
savings associations) (OCC); 12 CFR part 208,
appendix F, and 12 CFR part 225, appendix G
(Board).
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3. Calculation of Foreign Exposures for
Applicability of the Advanced
Approaches—Changes to Federal
Financial Institutions Economic Council
009
The agencies are revising the
advanced approaches rule to comport
with changes to the FFIEC’s Country
Exposure Report (FFIEC 009) that
occurred after the issuance of the
advanced approaches rule in 2007.
Specifically, the FFIEC 009 replaced the
term ‘‘local country claims’’ with the
term ‘‘foreign-office claims.’’
Accordingly, the agencies have made a
similar change under section 100, the
section of the final rule that makes the
rules applicable to a banking
organization that has consolidated total
on-balance sheet foreign exposures
equal to $10 billion or more. As a result,
to determine total on-balance sheet
foreign exposure, a banking organization
sums its adjusted cross-border claims,
local country claims, and cross-border
revaluation gains calculated in
accordance with FFIEC 009. Adjusted
cross-border claims equal total crossborder claims less claims with the head
office or guarantor located in another
country, plus redistributed guaranteed
amounts to the country of the head
office or guarantor.
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4. Applicability of the Final Rule
The agencies believe that once a
banking organization reaches the asset
size or level of foreign activity that
causes it to become subject to the
advanced approaches, that it should
remain subject to the advanced
approaches rule even if it subsequently
drops below the asset or foreign
exposure threshold. The agencies
believe that it is appropriate for the
primary Federal supervisor to evaluate
whether a banking organization’s
business or risk exposure has changed
after dropping below the thresholds in
a manner that it would no longer be
appropriate for the banking organization
to be subject to the advanced
approaches. As a result, consistent with
the proposal, the final rule clarifies that
once a banking organization is subject to
the advanced approaches rule under
subpart E, it remains subject to subpart
E until its primary Federal supervisor
determines that application of the rule
would not be appropriate in light of the
banking organization’s asset size, level
of complexity, risk profile, or scope of
operations. In connection with the
consideration of a banking
organization’s level of complexity, risk
profile, and scope of operations, the
agencies also may consider a banking
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organization’s interconnectedness and
other relevant risk-related factors.
5. Change to the Definition of
Probability of Default Related to
Seasoning
The advanced approaches rule
requires an upward adjustment to
estimated PD for segments of retail
exposures for which seasoning effects
are material. The rationale underlying
this requirement was the seasoning
pattern displayed by some types of retail
exposures—that is, the exposures have
very low default rates in their first year,
rising default rates in the next few years,
and declining default rates for the
remainder of their terms. Because of the
one-year internal ratings-based (IRB)
default horizon, capital based on the
very low PDs for newly originated, or
‘‘unseasoned,’’ loans would be
insufficient to cover the elevated risk in
subsequent years. The upward
seasoning adjustment to PD was
designed to ensure that banking
organizations would have sufficient
capital when default rates for such
segments rose predictably beginning in
year two.
Since the issuance of the advanced
approaches rule, the agencies have
found the seasoning provision to be
problematic. First, it is difficult to
ensure consistency across institutions,
given that there is no guidance or
criteria for determining when seasoning
is ‘‘material’’ or what magnitude of
upward adjustment to PD is
‘‘appropriate.’’ Second, the advanced
approaches rule lacks flexibility by
requiring an upward PD adjustment
whenever there is a significant
relationship between a segment’s
default rate and its age (since
origination). For example, the upward
PD adjustment may be inappropriate in
cases where (1) the outstanding balance
of a segment is falling faster over time
(due to defaults and prepayments) than
the default rate is rising; (2) the age
(since origination) distribution of a
portfolio is stable over time; or (3)
where the loans in a segment are
intended, with a high degree of
certainty, to be sold or securitized
within a short time period.
Therefore, consistent with the
proposal, the agencies are deleting the
regulatory seasoning provision and will
instead consider seasoning when
evaluating a firm’s assessment of its
capital adequacy from a supervisory
perspective. In addition to the
difficulties in applying the advanced
approaches rule’s seasoning
requirements discussed above, the
agencies believe that seasoning is more
appropriately considered from a
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supervisory perspective. First, seasoning
involves the determination of minimum
required capital for a period in excess of
the 12-month time horizon implicit in
the advanced approaches risk-based
capital ratio calculations. It thus falls
more appropriately under longer-term
capital planning and capital adequacy,
which are major focal points of the
internal capital adequacy assessment
process. Second, seasoning is a major
issue only where a banking organization
has a concentration of unseasoned
loans. The risk-based capital ratios do
not take concentrations of any kind into
account; however, they are an explicit
factor in the internal capital adequacy
assessment process.
6. Cash Items in Process of Collection
Under the current advanced
approaches rule, cash items in the
process of collection are not assigned a
risk-based capital treatment and, as a
result, are subject to a 100 percent risk
weight. Under the final rule, consistent
with the proposal, the agencies are
revising the advanced approaches rule
to risk weight cash items in the process
of collection at 20 percent of the
carrying value, as the agencies believe
that this treatment is more
commensurate with the risk of these
exposures. A corresponding provision is
included in section 32 of the final rule.
7. Change to the Definition of Qualifying
Revolving Exposure
The agencies and the FDIC proposed
modifying the definition of qualifying
revolving exposure (QRE) such that
certain unsecured and unconditionally
cancellable exposures where a banking
organization consistently imposes in
practice an upper exposure limit of
$100,000 and requires payment in full
every cycle would qualify as QRE.
Under the previous definition in the
advanced approaches rule, only
unsecured and unconditionally
cancellable revolving exposures with a
pre-established maximum exposure
amount of $100,000 or less (such as
credit cards) were classified as QRE.
Unsecured, unconditionally cancellable
exposures that require payment in full
and have no communicated maximum
exposure amount (often referred to as
‘‘charge cards’’) were instead classified
as ‘‘other retail.’’ For risk-based capital
purposes, this classification was
material and generally results in
substantially higher minimum required
capital to the extent that the exposure’s
asset value correlation (AVC) would
differ if classified as QRE (where it is
assigned an AVC of 4 percent) or other
retail (where AVC varies inversely with
through-the-cycle PD estimated at the
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segment level and can go as high as
almost 16 percent for very low PD
segments).
Under the proposed definition,
certain charge card products would
qualify as QRE. Charge card exposures
may be viewed as revolving in that there
is an ability to borrow despite a
requirement to pay in full. Commenters
agreed that charge cards should be
included as QRE because, compared to
credit cards, they generally exhibit
lower loss rates and loss volatility.
Where a banking organization
consistently imposes in practice an
upper exposure limit of $100,000 the
agencies believe that charge cards are
more closely aligned from a risk
perspective with credit cards than with
any type of ‘‘other retail’’ exposure and
are therefore amending the definition of
QRE in order to more appropriately
capture such products under the
definition of QRE. With respect to a
product with a balance that the
borrower is required to pay in full every
month, the exposure would qualify as
QRE under the final rule as long as its
balance does not in practice exceed
$100,000. If the balance of an exposure
were to exceed that amount, it would
represent evidence that such a limit is
not maintained in practice for the
segment of exposures in which that
exposure is placed for risk parameter
estimation purposes. As a result, that
segment of exposures would not qualify
as QRE over the next 24 month period.
In addition, the agencies believe that the
definition of QRE should be sufficiently
flexible to encompass products with
new features that were not envisioned at
the time of adopting the advanced
approaches rule, provided, however,
that the banking organization can
demonstrate to the satisfaction of the
primary Federal supervisor that the
performance and risk characteristics (in
particular the volatility of loss rates over
time) of the new product are consistent
with the definition and requirements of
QRE portfolios.
8. Trade-Related Letters of Credit
In 2011, the BCBS revised the Basel
II advanced internal ratings-based
approach to remove the one-year
maturity floor for trade finance
instruments. Consistent with this
revision, the proposed rule specified
that an exposure’s effective maturity
must be no greater than five years and
no less than one year, except that an
exposure’s effective maturity must be no
less than one day if the exposure is a
trade-related letter of credit, or if the
exposure has an original maturity of less
than one year and is not part of a
banking organization’s ongoing
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financing of the obligor. Commenters
requested clarification on whether
short-term self-liquidating trade finance
instruments would be considered
exempt from the one-year maturity
floor, as they do not constitute an
ongoing financing of the obligor. In
addition, commenters stated that
applying the proposed framework for
AVCs to trade-related letters of credit
would result in banking organizations
maintaining overly conservative capital
requirements in relation to the risk of
trade finance exposures, which could
reduce the availability of trade finance
and increase the cost of providing trade
finance for businesses globally. As a
result, commenters requested that trade
finance exposures be assigned a separate
AVC that would better reflect the
product’s low default rates and low
correlation.
The agencies believe that, in light of
the removal of the one-year maturity
floor, the proposed requirements for
trade-related letters of credit are
appropriate without a separate AVC. In
the final rule, the agencies are adopting
the treatment of trade-related letters of
credit as proposed. Under the final rule,
trade finance exposures that meet the
stated requirements above may be
assigned a maturity lower than one year.
Section 32 of the final rule includes a
provision that similarly recognizes the
low default rates of these exposures.
9. Defaulted Exposures That Are
Guaranteed by the U.S. Government
Under the current advanced
approaches rule, a banking organization
is required to apply an 8.0 percent
capital requirement to the EAD for each
wholesale exposure to a defaulted
obligor and for each segment of
defaulted retail exposures. The
advanced approaches rule does not
recognize yet-to-be paid protection in
the form of guarantees or insurance on
defaulted exposures. For example,
under certain programs, a U.S.
government agency that provides a
guarantee or insurance is not required to
pay on claims on exposures to defaulted
obligors or segments of defaulted retail
exposures until the collateral is sold.
The time period from default to sale of
collateral can be significant and the
exposure amount covered by such U.S.
sovereign guarantees or insurance can
be substantial.
In order to make the treatment for
exposures to defaulted obligors and
segments of defaulted retail exposures
more risk sensitive, the agencies have
decided to amend the advanced
approaches rule by assigning a 1.6
percent capital requirement to the
portion of the EAD for each wholesale
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exposure to a defaulted obligor and each
segment of defaulted retail exposures
that is covered by an eligible guarantee
from the U.S. government. The portion
of the exposure amount for each
wholesale exposure to a defaulted
obligor and each segment of defaulted
retail exposures not covered by an
eligible guarantee from the U.S.
government continues to be assigned an
8.0 percent capital requirement.
10. Stable Value Wraps
The agencies are clarifying that a
banking organization that provides
stable value protection, such as through
a stable value wrap that has provisions
and conditions that minimize the wrap’s
exposure to credit risk of the underlying
assets in the fund, must treat the
exposure as if it were an equity
derivative on an investment fund and
determine the adjusted carrying value of
the exposure as the sum of the adjusted
carrying values of any on-balance sheet
asset component determined according
to section 151(b)(1) and the off-balance
sheet component determined according
to section 151(b)(2). That is, the
adjusted carrying value is the effective
notional principal amount of the
exposure, the size of which is
equivalent to a hypothetical on-balance
sheet position in the underlying equity
instrument that would evidence the
same change in fair value (measured in
dollars) given a small change in the
price of the underlying equity
instrument without subtracting the
adjusted carrying value of the onbalance sheet component of the
exposure as calculated under the same
paragraph. Risk-weighted assets for such
an exposure is determined by applying
one of the three look-through
approaches as provided in section 154
of the final rule.
11. Treatment of Pre-Sold Construction
Loans and Multi-Family Residential
Loans
The final rule assigns either a 50
percent or a 100 percent risk weight to
certain one-to-four family residential
pre-sold construction loans under the
advanced approaches rule, consistent
with provisions of the RTCRRI Act.206
This treatment is consistent with the
treatment under the general risk-based
capital rules and under the standardized
approach.
F. Pillar 3 Disclosures
1. Frequency and Timeliness of
Disclosures
For purposes of the final rule, a
banking organization is required to
206 See
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provide certain qualitative and
quantitative public disclosures on a
quarterly, or in some cases, annual
basis, and these disclosures must be
‘‘timely.’’ Qualitative disclosures that
provide a general summary of a banking
organization’s risk-management
objectives and policies, reporting
system, and definitions may be
disclosed annually after the end of the
fourth calendar quarter, provided any
significant changes are disclosed in the
interim. In the preamble to the
advanced approaches rule, the agencies
indicated that quarterly disclosures
would be timely if they were provided
within 45 days after calendar quarterend. The preamble did not specify
expectations regarding annual
disclosures.
The agencies acknowledge that timing
of disclosures required under the federal
banking laws may not always coincide
with the timing of disclosures under
other federal laws, including federal
securities laws and their implementing
regulations by the SEC. The agencies
also indicated that a banking
organization may use disclosures made
pursuant to SEC, regulatory reporting,
and other disclosure requirements to
help meet its public disclosure
requirements under the advanced
approaches rule. For calendar quarters
that do not correspond to fiscal year
end, the agencies consider those
disclosures that are made within 45
days of the end of the calendar quarter
(or within 60 days for the limited
purpose of the banking organization’s
first reporting period in which it is
subject to the public disclosure
requirements) as timely. In general,
where a banking organization’s fiscal
year-end coincides with the end of a
calendar quarter, the agencies consider
qualitative and quantitative disclosures
to be timely if they are made no later
than the applicable SEC disclosure
deadline for the corresponding Form
10–K annual report. In cases where an
institution’s fiscal year end does not
coincide with the end of a calendar
quarter, the primary Federal supervisor
would consider the timeliness of
disclosures on a case-by-case basis. In
some cases, management may determine
that a significant change has occurred,
such that the most recent reported
amounts do not reflect the banking
organization’s capital adequacy and risk
profile. In those cases, a banking
organization needs to disclose the
general nature of these changes and
briefly describe how they are likely to
affect public disclosures going forward.
A banking organization should make
these interim disclosures as soon as
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practicable after the determination that
a significant change has occurred.
2. Enhanced Securitization Disclosure
Requirements
In view of the significant market
uncertainty during the recent financial
crisis caused by the lack of disclosures
regarding banking organizations’
securitization-related exposures, the
agencies believe that enhanced
disclosure requirements are appropriate.
Consistent with the disclosures
introduced by the 2009 Enhancements,
the proposal amended the qualitative
section for Table 9 disclosures
(Securitization) under section 173 to
include the following:
D The nature of the risks inherent in
a banking organization’s securitized
assets,
D A description of the policies that
monitor changes in the credit and
market risk of a banking organization’s
securitization exposures,
D A description of a banking
organization’s policy regarding the use
of credit risk mitigation for
securitization exposures,
D A list of the special purpose entities
a banking organization uses to securitize
exposures and the affiliated entities that
a bank manages or advises and that
invest in securitization exposures or the
referenced SPEs, and
D A summary of the banking
organization’s accounting policies for
securitization activities.
To the extent possible, the agencies
are implementing the disclosure
requirements included in the 2009
Enhancements in the final rule.
However, consistent with section 939A
of the Dodd-Frank Act, the tables do not
include those disclosure requirements
that are tied to the use of ratings.
3. Equity Holdings That Are Not
Covered Positions
The current advanced approaches rule
requires banking organizations to
include in their public disclosures a
discussion of ‘‘important policies
covering the valuation of and
accounting for equity holdings in the
banking book.’’ Since ‘‘banking book’’ is
not a defined term under the final rule,
the agencies refer to such exposures as
equity holdings that are not covered
positions in the final rule.
XIII. Market Risk Rule
On August 30, 2012, the agencies and
the FDIC revised their respective market
risk rules to better capture positions
subject to market risk, reduce procyclicality in market risk capital
requirements, enhance the rule’s
sensitivity to risks that were not
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adequately captured under the prior
regulatory measurement methodologies,
and increase transparency through
enhanced disclosures.207
As noted in the introduction of this
preamble, the agencies and the FDIC
proposed to expand the scope of the
market risk rule to include savings
associations and SLHCs, and to codify
the market risk rule in a manner similar
to the other regulatory capital rules in
the three proposals. In the final rule,
consistent with the proposal, the
agencies have also merged definitions
and made appropriate technical
changes.
As a general matter, a banking
organization that is subject to the market
risk rule will continue to exclude
covered positions (other than certain
foreign exchange and commodities
positions) when calculating its riskweighted assets under the other riskbased capital rules. Instead, the banking
organization must determine an
appropriate capital requirement for such
positions using the methodologies set
forth in the final market risk rule. The
banking organization then must
multiply its market risk capital
requirement by 12.5 to determine a riskweighted asset amount for its market
risk exposures and include that amount
in its standardized approach riskweighted assets and for an advanced
approaches banking organization’s
advanced approaches risk-weighted
assets.
The market risk rule is designed to
determine capital requirements for
trading assets based on general and
specific market risk associated with
these assets. General market risk is the
risk of loss in the market value of
positions resulting from broad market
movements, such as changes in the
general level of interest rates, equity
prices, foreign exchange rates, or
commodity prices. Specific market risk
is the risk of loss from changes in the
fair value of a position due to factors
other than broad market movements,
including event risk (changes in market
price due to unexpected events specific
to a particular obligor or position) and
default risk.
The agencies and the FDIC proposed
to apply the market risk rule to savings
associations and SLHCs. Consistent
with the proposal, the agencies in this
final rule have expanded the scope of
the market risk rule to savings
associations and covered SLHCs that
meet the stated thresholds. The market
risk rule applies to any savings
association or covered SLHC whose
trading activity (the gross sum of its
207 See
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trading assets and trading liabilities) is
equal to 10 percent or more of its total
assets or $1 billion or more. Each agency
retains the authority to apply its
respective market risk rule to any entity
under its jurisdiction, regardless of
whether it meets either of the thresholds
described above, if the agency deems it
necessary or appropriate for safe and
sound banking practices.
Application of the market risk rule to
all banking organizations with material
exposure to market risk is particularly
important because of banking
organizations’ increased exposure to
traded credit products, such as CDSs,
asset-backed securities and other
structured products, as well as other
less liquid products. In fact, many of the
August 2012 revisions to the market risk
rule were made in response to concerns
that arose during the recent financial
crisis when banking organizations
holding certain trading assets suffered
substantial losses. For example, in
addition to a market risk capital
requirement to account for general
market risk, the revised rules apply
more conservative standardized specific
risk capital requirements to most
securitization positions and implement
an additional incremental risk capital
requirement for a banking organization
that models specific risk for one or more
portfolios of debt or, if applicable,
equity positions. Additionally, to
address concerns about the appropriate
treatment of traded positions that have
limited price transparency, a banking
organization subject to the market risk
rule must have a well-defined valuation
process for all covered positions.
The agencies and the FDIC received
comments on the market risk rule. One
commenter asserted that the effective
date for application of the market risk
rule (and the advanced approaches rule)
to SLHCs should be deferred until at
least July 21, 2015. This commenter also
asserted that SLHCs with substantial
insurance operations should be exempt
from the advanced approaches and
market risk rules if their subsidiary bank
or savings association comprised less
than 5 percent or 10 percent of the total
assets of the SLHC. As a general matter,
savings associations and SLHCs do not
engage in trading activity to a
substantial degree. However, the
agencies believe that any savings
association or covered SLHC whose
trading activity grows to the extent that
it meets either of the thresholds should
hold capital commensurate with the risk
of the trading activity and should have
in place the prudential risk-management
systems and processes required under
the market risk rule. Therefore, it is
appropriate to expand the scope of the
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market risk rule to apply to savings
associations and covered SLHCs as of
January 1, 2015.
Another commenter asserted that the
agencies and the FDIC should establish
standardized capital requirements for
trading operations rather than relying on
risk modeling techniques because there
is no way for regulators or market
participants to judge whether bank
calculations of market risk are
meaningful. Regarding the use of
standardized requirements for trading
operations rather than reliance on risk
modeling, banking organizations’
models are subject to initial approval
and ongoing review under the market
risk rule. The agencies are aware that
the BCBS is considering, among other
options, greater use of standardized
approaches for market risk. The
agencies would consider modifications
to the international market risk
framework when and if it is revised.
One commenter asserted that
regulations should increase the cost of
excessive use of short-term borrowing to
fund long maturity assets. The agencies
are considering the implications of
short-term funding from several
perspectives outside of the regulatory
capital framework. Specifically, the
agencies expect short-term funding risks
would be a potential area of focus in
forthcoming Basel III liquidity and
enhanced prudential standards
regulations.
The agencies also have adopted
conforming changes to certain elements
of the market risk rule to reflect changes
that are being made to other aspects of
the regulatory capital framework. These
changes are designed to correspond to
the changes to the CRC references and
treatment of securitization exposures
under subparts D and E of the final rule,
which are discussed more fully in the
standardized and advanced approaches
sections. See sections VIII.B and XII.C of
this preamble for a discussion of these
changes.
More specifically, the market risk rule
is being amended to incorporate a
revised definition of parameter W in the
SSFA. As discussed above, the agencies
and the FDIC received comment on the
existing definition, which assessed a
capital penalty if borrowers exercised
contractual rights to defer payment of
principal or interest for more than 90
days on exposures underlying a
securitization. In response to
commenters, the agencies are modifying
this definition to exclude all loans
issued under Federally-guaranteed
student loan programs, and certain
consumer loans (including nonFederally guaranteed student loans)
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62147
from being included in this component
of parameter W.
The agencies have made a technical
amendment to the rule with respect to
the covered position definition.
Previously, the definition of covered
position excluded equity positions that
are not publicly traded. The agencies
have refined this exception such that a
covered position may include a position
in a non-publicly traded investment
company, as defined in and registered
with the SEC under the Investment
Company Act of 1940 (15 U.S.C. 80 a1 et seq.) (or its non-U.S. equivalent),
provided that all the underlying equities
held by the investment company are
publicly traded. The agencies believe
that a ‘‘look-through’’ approach is
appropriate in these circumstances
because of the of the liquidity of the
underlying positions, so long as the
other conditions of a covered position
are satisfied.
The agencies also have clarified
where a banking organization subject to
the market risk rule must make its
required market risk disclosures and
require that these disclosures be timely.
The banking organization must provide
its quantitative disclosures after each
calendar quarter. In addition, the final
rule clarifies that a banking organization
must provide its qualitative disclosures
at least annually, after the end of the
fourth calendar quarter, provided any
significant changes are disclosed in the
interim.
The agencies acknowledge that the
timing of disclosures under the federal
banking laws may not always coincide
with the timing of disclosures required
under other federal laws, including
disclosures required under the federal
securities laws and their implementing
regulations by the SEC. For calendar
quarters that do not correspond to fiscal
year end, the agencies consider those
disclosures that are made within 45
days of the end of the calendar quarter
(or within 60 days for the limited
purpose of the banking organization’s
first reporting period in which it is
subject to the rule) as timely. In general,
where a banking organization’s fiscal
year-end coincides with the end of a
calendar quarter, the agencies consider
qualitative and quantitative disclosures
to be timely if they are made no later
than the applicable SEC disclosure
deadline for the corresponding Form
10–K annual report. In cases where an
institution’s fiscal year end does not
coincide with the end of a calendar
quarter, the primary Federal supervisor
would consider the timeliness of
disclosures on a case-by-case basis. In
some cases, management may determine
that a significant change has occurred,
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such that the most recent reported
amounts do not reflect the banking
organization’s capital adequacy and risk
profile. In those cases, a banking
organization needs to disclose the
general nature of these changes and
briefly describe how they are likely to
affect public disclosures going forward.
A banking organization should make
these interim disclosures as soon as
practicable after the determination that
a significant change has occurred.
The final rule also clarifies that a
banking organization’s management
may provide all of the disclosures
required by the market risk rule in one
place on the banking organization’s
public Web site or may provide the
disclosures in more than one public
financial report or other regulatory
reports, provided that the banking
organization publicly provides a
summary table specifically indicating
the location(s) of all such disclosures.
The Board also is issuing a notice of
proposed rulemaking concurrently with
this final rule. The notice of proposed
rulemaking would revise the current
market risk rule in Appendix E to
incorporate the changes to the CRC
references and parameter W, as
discussed above.
XIV. Additional OCC Technical
Amendments
In addition to the changes described
above, the OCC proposed to redesignate
subpart C (Establishment of Minimum
Capital Ratios for an Individual Bank),
subpart D (Enforcement), and subpart E
(Issuance of a Directive), as subparts H,
I, and J, respectively. The OCC also
proposed to redesignate section 3.100
(Capital and Surplus), as subpart K. The
OCC proposed to carry over
redesignated subpart K, which includes
definitions of the terms ‘‘capital’’ and
‘‘surplus’’ and related definitions that
are used for determining statutory limits
applicable to national banks that are
based on capital and surplus. In
addition, the OCC proposed to remove
appendices A, B, and C to part 3
because they would be replaced with
the new proposed framework. Finally,
as part of the integration of the rules
governing national banks and Federal
savings associations, the OCC proposed
to make part 3 applicable to Federal
savings associations, make other nonsubstantive, technical amendments, and
rescind part 167 (including appendix C)
(Capital).
The OCC received no comments on
these proposed changes and therefore is
adopting the proposal as final, except
for the following changes. The final rule
retains the existing 12 CFR part 3,
appendices A and B for national banks
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and part 167 (excluding appendix C) for
Federal savings associations. Because
the impact of many of the deductions
and adjustments to the revised
definition of capital are phased in over
several years, national banks and
Federal savings associations will need
to use the existing rules at 12 CFR part
3, appendix A and 12 CFR part 167
(excluding appendix C), respectively,
pertaining to the definition of capital to
determine certain baseline regulatory
capital amounts. Additionally, because
the standardized approach riskweighted asset calculations will not
become effective until January 1, 2015,
national banks and Federal savings
associations that are not subject to the
advanced approaches risk-based capital
rules will be required to continue using
the risk-weighted asset calculations set
forth at 12 CFR part 3, appendix A and
12 CFR part 167 (excluding appendix
C), respectively, from January 1, 2014,
until December 31, 2014. National banks
that are subject to the market risk rule
(12 CFR part 3, appendix B), but not the
advanced approaches risk-based capital
rules, will need to use the 12 CFR part
3, appendix B, from January 1, 2014,
until December 31, 2014. Finally, as
noted earlier in this preamble, national
banks and Federal savings associations
that are subject to the advanced
approaches risk-based rules must
calculate their risk-based capital floor
using the risk-weighted asset
calculations set forth at 12 CFR part 3,
appendix A, and 12 CFR part 167
(excluding appendix C), respectively,
through December 31, 2014. Beginning
on January 1, 2015, national banks and
Federal savings associations subject to
the advanced approaches risk-based
capital rules will use the standardized
approach risk-weighted asset
calculations, set forth in new subpart D,
when determining their risk-based
capital floor.
The final rule also removes existing
12 CFR part 167, appendix C (RiskBased Capital Requirements—InternalRatings-Based and Advanced
Measurement Approaches) because it is
being replaced with new subpart E.
Finally, as described in section IV.H
of this preamble, in 12 CFR 6.4(b)(5) and
(c)(5) this final rule replaces the phrase
‘‘total adjusted assets’’ with the phrase
‘‘average total assets’’ in 12 CFR
6.4(b)(5) and (c)(5).
The OCC may need to make
additional technical and conforming
amendments to other OCC rules, such as
§ 5.46, subordinated debt, which
contains cross references to part 3 that
are being changed pursuant to this final
rule. The OCC intends to issue a
separate rulemaking to amend other
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non-capital regulations that contain
cross-references to provisions of the
existing capital rules at 12 CFR part 3
and appendices A, B, or C (national
banks) and 12 CFR part 167 and
appendix C (Federal savings
associations), as necessary, to reference
the appropriate corresponding
provisions of the revised rules.
With the adoption of this final rule, as
a result of the integration of the rules
governing national banks and Federal
savings association, all of part 3 will be
applicable to Federal savings
associations, except for subpart K
(Interpretations). Thus, under the final
rule, a Federal savings association will
comply with redesignated subpart H
(Establishment of minimum capital
ratios for an individual bank or
individual Federal savings association),
subpart I (Enforcement), and subpart J
(Issuance of a directive), rather than 12
CFR 167.3 (Individual minimum capital
requirements) and 167.4 (Capital
directives). The provisions of subparts
H, I, and J are substantively the same as
12 CFR 167.3 and 167.4, with a few
exceptions. Sections 3.402
(Applicability) and 167.3(b)
(Appropriate considerations for
establishing individual minimum
capital requirements) both state that the
OCC may require higher minimum
capital ratios for an individual bank in
view of its circumstances and provide
examples of such circumstances.
Likewise, both sections 3.403
(Standards for determining individual
minimum capital ratios) and 167.3(c)
(Standards for determination of
appropriate minimum capital
requirements) explain that the
determination of the appropriate
minimum capital level for an individual
national bank or Federal savings
association, respectively, is in part a
subjective judgment based on agency
expertise and these sections of the
respective national bank and Federal
savings association regulations provide
a list factors that may be considered.
The list of examples in sections 3.402
and 167.3(b) and in sections 3.403 and
167.3(c) are similar, but not identical in
all respects; and consistent with the
proposal, the final rule makes no change
to the list of examples in sections 3.402
and 3.403. The OCC notes that, while
the final rule omits some of the
examples in sections 167.3(b) and (c),
because the list of examples is
illustrative and not exclusive, the OCC
retains the ability to consider those
omitted examples and all other relevant
items when determining individual
minimum capital requirements.
The procedures in § 167.3(d) for
responding to a notice of proposed
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minimum capital ratios provide that the
OCC may shorten the 30-day response
period for good cause and limit good
cause to three specific situations. A
Federal savings association should be
aware that, in addition to listing specific
circumstances when the OCC may
shorten the response time, the
comparable provision in § 3.404(b)(1) of
the final rule provides that the OCC, in
its discretion, may shorten the 30-day
response time. Thus, there may be
additional circumstances in which the
OCC may shorten the response time for
a Federal savings association.
Section 167.3(d)(3) (Decision) states
that the OCC’s written decision on the
individual minimum capital
requirement with respect to a Federal
savings association represents final
agency action. Consistent with the
proposal, § 3.404(c) (Decision) of the
final rule does not include this
statement. The OCC notes that inclusion
of this statement is unnecessary because
internal appeals of informal OCC
enforcement actions, such as a decision
on a Federal savings association’s
minimum capital requirement, are
reviewable by the OCC’s Ombudsman’s
Office. Therefore, omitting this
statement in § 3.404(c) will have no
substantive effect.
Sections 3.601 (Purpose and scope)
and § 167.4(a) (Issuance of a capital
directive), both of which address
issuance of a capital directive, are very
similar but not identical. The final rule
adopts § 3.601 as proposed. In some
cases § 167.4(a) includes more detail
than § 3.601, and in some cases § 3.601
includes more detail than § 167.4(a). For
example, § 3.601(b) states that violation
of a directive may result in assessment
of civil money penalties in accordance
with 12 U.S.C. 3909(d), whereas
§ 167.4(a) does not include such a
statement. However, because the
International Lending Supervision Act
(ILSA) applies to Federal savings
associations and 12 U.S.C. 3909(d)
states that the violation of any rule,
regulation or order issued under the
ILSA may result in a civil money
penalty, the OCC has concluded that
inclusion of this language in § 3.601 will
have no substantive impact on Federal
savings associations. Furthermore, the
OCC has concluded that,
notwithstanding any other minor
differences between § 3.601 and
§ 167.4(a), those changes will have no
substantive impact on Federal savings
associations.
XV. Abbreviations
ABCP Asset-Backed Commercial Paper
ADC Acquisition, Development, or
Construction
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AFS Available For Sale
ALLL Allowance for Loan and Lease Losses
AOCI Accumulated Other Comprehensive
Income
AVC Asset Value Correlation
BCBS Basel Committee on Banking
Supervision
BCBS FAQ Basel Committee on Banking
Supervision Frequently Asked Questions
BHC Bank Holding Company
CCF Credit Conversion Factor
CCP Central Counterparty
CDFI Community Development Financial
Institution
CDS Credit Default Swap
CDSind Index Credit Default Swap
CEIO Credit-Enhancing Interest-Only Strip
CEM Current Exposure Method
CFR Code of Federal Regulations
CFPB Consumer Financial Protection
Bureau
CFTC Commodity Futures Trading
Commission
CPSS Committee on Payment and
Settlement Systems
CRC Country Risk Classifications
CUSIP Committee on Uniform Securities
Identification Procedures
CVA Credit Valuation Adjustment
DAC Deferred Acquisition Cost
DCO Derivatives Clearing Organizations
DTA Deferred Tax Asset
DTL Deferred Tax Liability
DvP Delivery-versus-Payment
E Measure of Effectiveness
EAD Exposure at Default
ECL Expected Credit Loss
EE Expected Exposure
EPE Expected Positive Exposure
ERISA Employee Retirement Income
Security Act of 1974
ESOP Employee Stock Ownership Plan
FDIC Federal Deposit Insurance
Corporation
FDICIA Federal Deposit Insurance
Corporation Improvement Act of 1991
FFIEC Federal Financial Institutions
Examination Council
FHA Federal Housing Administration
FHLB Federal Home Loan Bank
FHLMC Federal Home Loan Mortgage
Corporation
FIRREA Financial Institutions, Reform,
Recovery and Enforcement Act
FMU Financial Market Utility
FNMA Federal National Mortgage
Association
FRFA Final Regulatory Flexibility Act
GAAP U.S. Generally Accepted Accounting
Principles
GNMA Government National Mortgage
Association
GSE Government-Sponsored Enterprise
HAMP Home Affordable Mortgage Program
HOLA Home Owners’ Loan Act
HTM Held-To-Maturity
HVCRE High-Volatility Commercial Real
Estate
IFRS International Financial Reporting
Standards
IMM Internal Models Methodology
IOSCO International Organization of
Securities Commissions
IRB Internal Ratings-Based
IRFA Initial Regulatory Flexibility Analysis
LGD Loss Given Default
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LTV Loan-to-Value Ratio
M Effective Maturity
MBS Mortgage-backed Security
MDB Multilateral Development Bank
MDI Minority Depository Institution
MHC Mutual Holding Company
MSA Mortgage Servicing Assets
NPR Notice of Proposed Rulemaking
NRSRO Nationally Recognized Statistical
Rating Organization
OCC Office of the Comptroller of the
Currency
OECD Organization for Economic Cooperation and Development
OMB Office of Management and Budget
OTC Over-the-Counter
OTS Office of Thrift Supervision
PCA Prompt Corrective Action
PCCR Purchased Credit Card Relationship
PD Probability of Default
PFE Potential Future Exposure
PMI Private Mortgage Insurance
PMSR Purchased Mortgage Servicing Right
PRA Paperwork Reduction Act of 1995
PSE Public Sector Entities
PvP Payment-versus-Payment
QCCP Qualifying Central Counterparty
QIS Quantitative Impact Study
QM Qualified Mortgages
QRE Qualifying Revolving Exposure
RBA Ratings-Based Approach
RBC Risk-Based Capital
REIT Real Estate Investment Trust
Re-REMIC Resecuritization of Real Estate
Mortgage Investment Conduit
RFA Regulatory Flexibility Act
RTCRRI Act Resolution Trust Corporation
Refinancing, Restructuring, and
Improvement Act of 1991
RVC Ratio of Value Change
SAP Statutory Accounting Principles
SEC U.S. Securities and Exchange
Commission
SFA Supervisory Formula Approach
SLHC Savings and Loan Holding Company
SPE Special Purpose Entity
SR Supervision and Regulation Letter
SRWA Simple Risk-Weight Approach
SSFA Simplified Supervisory Formula
Approach
TruPS Trust Preferred Security
TruPS CDO Trust Preferred Security
Collateralized Debt Obligation
UMRA Unfunded Mandates Reform Act of
1995
U.S.C. United States Code
VA Veterans Administration
VaR Value-at-Risk
VOBA Value of Business Acquired
WAM Weighted Average Maturity
XVI. Regulatory Flexibility Act
In general, section 4 of the Regulatory
Flexibility Act (5 U.S.C. 604) (RFA)
requires an agency to prepare a final
regulatory flexibility analysis (FRFA),
for a final rule unless the agency
certifies that the rule will not, if
promulgated, have a significant
economic impact on a substantial
number of small entities (defined as of
July 2, 2013, for purposes of the RFA to
include banking entities with total
assets of $175 million or less, and
beginning on July 22, 2013, to include
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banking entities with total assets of $500
million or less). Pursuant to the RFA,
the agency must make the final
regulatory flexibility analysis available
to members of the public and must
publish the final regulatory flexibility
analysis, or a summary thereof, in the
Federal Register. In accordance with
section 4 of the RFA, the agencies are
publishing the following summary of
their final regulatory flexibility
analyses.208
For purposes of their respective
FRFAs, the OCC analyzed the potential
economic impact of the final rule on the
small entities it regulates, including
small national banks and small Federal
savings associations; and the Board
analyzed the potential economic impact
on the small entities it regulates
including small state member banks,
small bank holding companies and
small savings and loan holding
companies.
As discussed in more detail in section
E, below, this final rule may have a
significant economic impact on a
substantial number of the small entities
under their respective jurisdictions.
Accordingly, the agencies have prepared
the following FRFA pursuant to the
RFA.
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A. Statement of the Need for, and
Objectives of, the Final Rule
As discussed in the SUPPLEMENTARY
INFORMATION of the preamble to this final
rule, the agencies are revising their
regulatory capital requirements to
promote safe and sound banking
practices, implement Basel III and other
aspects of the Basel capital framework,
harmonize capital requirements across
different types of insured depository
institutions and depository institution
holding companies, and codify capital
requirements.
Additionally, this final rule satisfies
certain requirements under the Dodd208 Each agency published separate summaries of
their initial regulatory flexibility analyses (IRFAs)
with each of the proposed rules in the three NPRs
in accordance with Section 3(a) of the Regulatory
Flexibility Act, 5 U.S.C. 603. In the IRFAs provided
in connection with the proposed rules, each agency
requested comment on all aspects of the IRFAs,
and, in particular, on any significant alternatives to
the proposed rules applicable to covered small
banking organizations that would minimize their
impact on those entities. In the IRFAs provided by
the OCC and the FDIC in connection with the
advanced approach proposed rule, the OCC and the
FDIC determined that there would not be a
significant economic impact on a substantial
number of small banking organizations and
published a certification and a short explanatory
statement pursuant to section 605(b) of the RFA. In
the IRFA provided by the Board in connection with
the advanced approach proposed rule, the Board
provided the information required by section 603(a)
of the RFA and concluded that there would not be
a significant economic impact on a substantial
number of small banking organizations.
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Frank Act by (1) revising regulatory
capital requirements to remove all
references to, and requirements of
reliance on, credit ratings,209 and (2)
imposing new or revised minimum
capital requirements on certain insured
depository institutions and depository
institution holding companies.210
Under section 38(c)(1) of the Federal
Deposit Insurance Act, the agencies are
required to prescribe capital standards
for insured depository institutions that
they regulate.211 The agencies also must
‘‘cause banking institutions to achieve
and maintain adequate capital by
establishing minimum levels of capital
for such banking institutions’’ under the
International Lending Supervision
Act.212 In addition, among other
authorities, the Board may establish
capital requirements for member banks
under the Federal Reserve Act,213 for
bank holding companies under the Bank
Holding Company Act,214 and for
savings and loan holding companies
under the Home Owners Loan Act.215
B. Summary and Assessment of
Significant Issues Raised by Public
Comments in Response to the IRFAs,
and a Statement of Changes Made as a
Result of These Comments
The agencies and the FDIC received
three public comments directly
addressing the initial regulatory
flexibility analyses (IRFAs). One
commenter questioned the FDIC’s
assumption that risk-weighted assets
would increase only 10 percent and
questioned reliance on Call Report data
for this assumption, as the commenter
asserted that existing Call Report data
does not contain the information
required to accurately analyze the
proposal’s impact on risk-weighted
assets (for example, under the
Standardized Approach NPR, an
increase in the risk weights for 1–4
family residential mortgage exposures
that are balloon mortgages). The
commenters also expressed general
concern that the agencies and the FDIC
were underestimating the compliance
cost of the proposed rules. For instance,
one commenter questioned whether
small banking organizations would have
the information required to determine
the applicable risk weights for
residential mortgage exposures, and
stated that the cost of applying the
proposed standards to existing
209 See
15 U.S.C. 78o–7, note.
12 U.S.C. 5371.
211 See 12 U.S.C. 1831o(c).
212 See 12 U.S.C. 3907.
213 See 12 U.S.C. 321–338.
214 See 12 U.S.C. 1844.
215 See 12 U.S.C 1467a(g)(1).
210 See
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exposures was underestimated. Another
commenter stated that the agencies and
the FDIC did not adequately consider
the additional costs relating to new
reporting systems, assimilating data,
and preparing reports required under
the proposed rules.
To measure the potential impact on
small entities for the purposes of their
respective IRFAs, the agencies used the
most current regulatory reporting data
available and, to address information
gaps, they applied conservative
assumptions. The agencies considered
the comments they received on the
potential impact of the proposed rules,
and, as discussed in Item F, below,
made significant revisions to the final
rule in response to the concerns
expressed regarding the potential
burden on small banking organizations.
Commenters expressed concern that
the agencies and the FDIC did not use
a uniform methodology for conducting
their IRFAs and suggested that the
agencies and the FDIC should have
compared their analyses prior to
publishing the proposed rules.
The agencies and the FDIC
coordinated closely in conducting the
IRFAs to maximize consistency among
the methodologies used for determining
the potential impact on the entities
regulated by each agency. However, the
agencies and the FDIC prepared the
individual analyses in recognition of the
differences among the organizations that
each agency supervises. In preparing
their respective FRFAs, the agencies and
the FDIC continued to coordinate
closely in order to ensure maximum
consistency and comparability.
One commenter questioned the
alternatives described in the IRFAs.
This commenter asserted that the
alternatives were counter-productive
and added complexity to the capital
framework without any meaningful
benefit. As discussed throughout the
preamble and in Item F, below, the
agencies have responded to
commenters’ concerns and sought to
mitigate the potential compliance
burden on community banking
organizations throughout the final rule.
The agencies and the FDIC also
received a number of more general
comments regarding the overall burden
of the proposed rules. For example,
many commenters expressed concern
that the complexity and implementation
cost of the proposed rules would exceed
the expected benefit. According to these
commenters, implementation of the
proposed rules would require software
upgrades for new internal reporting
systems, increased employee training,
and the hiring of additional employees
for compliance purposes.
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A few commenters also urged the
agencies and the FDIC to recognize that
compliance costs have increased
significantly over recent years due to
other regulatory changes. As discussed
throughout the preamble and in Item F,
below, the agencies recognize the
potential compliance costs associated
with the proposals. Accordingly, for
purposes of the final rule the agencies
modified certain requirements of the
proposals, such as the proposed
mortgage treatment, to help to reduce
the compliance burden on small
banking organizations.
C. Response to Comments Filed by the
Chief Counsel for Advocacy of the Small
Business Administration, and Statement
of Changes Made as a Result of the
Comment
The Chief Counsel for Advocacy of
the Small Business Administration
(CCA) filed a letter with the agencies
and the FDIC providing comments on
the proposed rules. The CCA generally
commended the agencies and the FDIC
for the IRFAs provided with the
proposed rules, and specifically
commended the agencies and the FDIC
for considering the cumulative
economic impact of the proposals on
small banking organizations. The CCA
acknowledged that the agencies and the
FDIC provided lists of alternatives being
considered, but encouraged the agencies
and the FDIC to provide more detailed
discussion of these alternatives and the
potential burden reductions associated
with the alternatives.
The CCA acknowledged that the OCC
and the FDIC had certified that the
advanced approaches proposed rule
would not have a significant economic
impact on a substantial number of small
banking organizations. The CCA noted
that the Board did not provide such a
certification for the advanced
approaches proposed rule and suggested
that the Board either provide the
certification for the advanced
approaches proposed rule or publish a
more detailed IRFA, if public comments
indicated that the advanced approaches
proposed rule would have a significant
economic impact on a substantial
number of small banking organizations.
The CCA encouraged ‘‘the agencies to
allow small banks to continue under the
current framework of Basel I.’’ The CCA
also urged the agencies and the FDIC to
give careful consideration to comments
discussing the impact of the proposed
rules on small financial institutions and
to analyze possible alternatives to
reduce this impact.
The CCA expressed concern that
aspects of the proposals could be
problematic and onerous for small
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community banking organizations. The
CCA stated that the proposed rules were
designed for large, international banks
and not adapted to the circumstances of
community banking organizations.
Specifically, the CCA expressed concern
over higher risk weights for certain
products, which, the CCA argued, could
drive community banking organizations
into products carrying additional risks.
The CCA also noted heightened
compliance and technology costs
associated with implementing the
proposed rules and raised the
possibility that community banking
organizations may exit the mortgage
market.
Although the new regulatory capital
framework will carry costs, the
supervisory interest in improved and
uniform capital standards at the level of
individual banking organizations, as
well as the expected improvements in
the safety and soundness of the U.S.
banking system, should outweigh the
increased burden on small banking
organizations. The agencies carefully
considered all comments received and,
in particular, the comments that
addressed the potential impact of the
proposed rules on small banking
organizations. As discussed throughout
the preamble and in Item F below, the
agencies have made significant revisions
to the proposed rules that address the
concerns raised in the CCA’s comment,
including with respect to the treatment
of AOCI, trust preferred securities
issued by depository holding companies
with less than $15 billion in total
consolidated assets as of December 31,
2009, and mortgages.
rule does not apply to small bank
holding companies that are not engaged
in significant nonbanking activities, do
not conduct significant off-balance sheet
activities, and do not have a material
amount of debt or equity securities
outstanding that are registered with the
SEC. These small bank holding
companies remain subject to the Board’s
Small Bank Holding Company Policy
Statement.218 Small state member banks
and small savings and loan holding
companies would be subject to the
proposals in this rule.
Under the $175 million threshold, as
of December 31, 2012, the OCC regulates
737 small entities. Under the $500
million threshold, the OCC regulates
1,291 small entities.219
D. Description and Estimate of Small
Entities Affected by the Final Rule
December 31, 2012, there were approximately 2,259
small bank holding companies and approximately
145 small savings and loan holding companies.
218 See 12 CFR part 225, appendix C. Section 171
of the Dodd-Frank provides an exemption from its
requirements for bank holding companies subject to
the Small Bank Holding Company Policy Statement
(as in effect on May 19, 2010). Section 171 does not
provide a similar exemption for small savings and
loan holding companies and they are therefore
subject to the proposals. 12 U.S.C. 5371(b)(5)(C).
219 The OCC has calculated the number of small
entities based on the SBA’s size thresholds for
commercial banks and savings institutions, and
trust companies. Consistent with the General
Principles of Affiliation 13 CFR § 121.103(a), the
OCC counts the assets of affiliated financial
institutions when determining if the OCC should
classify a bank the OCC supervises as a small entity.
The OCC used December 31, 2012 to determine size
because a ‘‘financial institution’s assets are
determined by averaging the assets reported on its
four quarterly financial statements for the preceding
year.’’ See footnote 8 of the U.S. Small Business
Administration’s Table of Size Standards.
220 Banking organizations subject to the advanced
approaches rules also would be required in 2018 to
achieve a minimum tier 1 capital to total leverage
exposure ratio (the supplementary leverage ratio) of
3 percent. Advanced approaches banking
organizations should refer to section 10 of subpart
Under regulations issued by the Small
Business Administration, a small entity
includes a depository institution, bank
holding company, or savings and loan
holding company with total assets of
$175 million or less and beginning July
22, 2013, total assets of $500 million or
less (a small banking organization).216
As of March 31, 2013, the Board
supervised approximately 636 small
state member banks. As of December 31,
2012, there were approximately 3,802
small bank holding companies and
approximately 290 small savings and
loan holding companies.217 The final
216 See 13 CFR 121.201. Effective July 22, 2013,
the Small Business Administration revised the size
standards for banking organizations to $500 million
in assets from $175 million in assets. 78 FR 37409
(June 20, 2013).
217 Under the prior Small Business
Administration threshold of $175 million in assets,
as of March 31, 2013 the Board supervised
approximately 369 small state member banks. As of
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E. Projected Reporting, Recordkeeping,
and Other Compliance Requirements
The final rule may impact covered
small banking organizations in several
ways. The final rule affects covered
small banking organizations’ regulatory
capital requirements by changing the
qualifying criteria for regulatory capital,
including mandatory deductions and
adjustments, and modifying the risk
weight treatment for some exposures.
The rule also requires covered small
banking organizations to meet a new
minimum common equity tier 1 to riskweighted assets ratio of 4.5 percent and
an increased minimum tier 1 capital to
risk-weighted assets risk-based capital
ratio of 6 percent. Under the final rule,
all banking organizations would remain
subject to a minimum tier 1 leverage
ratio of no more than 4 percent and an
8 percent total capital ratio.220 The rule
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imposes limitations on capital
distributions and discretionary bonus
payments for covered small banking
organizations that do not hold a buffer
of common equity tier 1 capital above
the minimum ratios.
For those covered small banking
organizations that do not engage in
securitization activities, derivatives
activities, and do not have exposure to
foreign sovereigns or equities, there
would be limited changes to the way
these small banking organizations are
required to calculate risk-weighted
assets. For these organizations, the only
two risk weights that would change are
those that relate to past due exposures
and acquisition and development real
estate loans.
The final rule includes other changes
to the general risk-based capital
requirements that address the
calculation of risk-weighted assets:
• Provides a more risk-sensitive
approach to exposures to non-U.S.
sovereigns and non-U.S. public sector
entities;
• Replaces references to credit ratings
with new measures of creditworthiness;
• Provides more comprehensive
recognition of collateral and guarantees;
and
• Provides a more favorable capital
treatment for transactions cleared
through qualifying central
counterparties.221
As a result of the new requirements,
some covered small banking
organizations may have to alter their
capital structure (including by raising
new capital or increasing retention of
earnings) in order to achieve the new
minimum capital requirements and
avoid restrictions on distributions of
capital and discretionary bonus
payments.
The agencies have excluded from this
analysis any burden associated with
changes to the Consolidated Reports of
Income and Condition for banks (FFIEC
031 and 041; OMB Nos. 7100–0036,
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B of the proposed rule and section II.B of the
preamble for a more detailed discussion of the
applicable minimum capital ratios.
221 Section 939A of the Dodd-Frank Act requires
federal agencies to remove references to credit
ratings from regulations and replace credit ratings
with appropriate alternatives. The final rule
introduces alternative measures of creditworthiness
for foreign debt, securitization positions, and
resecuritization positions.
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3064–0052, 1557–0081), the Financial
Statements for Bank Holding Companies
(FR Y–9; OMB No. 7100–0128), and the
Capital Assessments and Stress Testing
information collection (FR Y–14A/Q/M;
OMB No. 7100–0341). The agencies are
proposing information collection
changes to reflect the requirements of
the final rule, and are publishing
separately for comment on the
regulatory reporting requirements that
will include associated estimates of
burden. Further analysis of the
projected reporting requirements
imposed by the final rule is located in
the Paperwork Reduction Act section,
below.
The agencies estimate that
managerial/technical, senior
management, legal counsel, and
administrative/junior analyst skills will
be necessary for the preparation of
reports and records related to this final
rule.
Board
To estimate the cost of capital needed
to comply with the final rule, the Board
estimated common equity tier 1, tier 1,
and total risk-based capital as defined
under the more stringent eligibility
standards for capital instruments. The
Board also adjusted risk-weighted assets
for each banking organization to
estimate the impact of compliance with
the changes under final rule and then
compared each banking organization’s
risk-based capital ratios to the higher
minimums required under the final rule.
If a banking organization’s new measure
of capital under the final rule would not
meet the minimums required for
‘‘adequately-capitalized’’ under the final
rule, the Board considered that
difference to be a ‘‘shortfall’’, or the
amount of capital that a banking
organization would need to raise in
order to comply with the rule.222
To estimate each small state member
bank’s capital risk-based capital ratios
under the final rule, the Board used
currently available data from the
222 The Board’s analysis assumed that the changes
included in the final rule were on a fully phasedin basis. In addition, for the purposes of this
analysis, banking organizations that did not meet
the minimum requirements (undercapitalized
institutions) under the current rules were excluded
in order to isolate the effect of the rule on
institutions that were otherwise adequately or wellcapitalized.
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quarterly Call Reports. The Board
arrived at estimates of the new
numerators of the capital ratios by
combining various regulatory reporting
items to reflect definitional changes to
common equity tier 1 capital, tier 1
capital, and total capital as described in
the final rule. The capital ratio
denominator, risk-weighted assets, will
also change under the final rule. The
uniqueness of each institution’s asset
portfolio will cause the direction and
extent of the change in the denominator
to vary from institution to institution.
The Board, however, was able to arrive
at a reasonable proxy for risk-weighted
assets under the standardized approach
in the final rule by using information
that is in the Call Reports. In particular,
the Board adjusted foreign exposures,
high volatility commercial real estate,
past-due loans, and securitization
exposures to account for new risk
weights under the final rule.
Using the estimates of the new capital
levels and standardized risk-weighted
assets under the final rule, the Board
estimated the capital shortfall each
banking organization would encounter
if the rule was fully phased in, as
discussed above. Table 27 shows the
Board’s estimates of the number of state
member banks that would not meet the
minimum capital requirements
according to Call Report data as of
March 30, 2013. This table also shows
the projected Basel III capital shortfall
for those banking organizations were the
final rule fully implemented. Because
institutions must simultaneously meet
all of the minimum capital
requirements, the largest shortfall
amount represents our estimate of the
amount of capital Board-regulated
banking organizations will need to
accumulate to meet new minimum
capital requirements under the final
rule, fully implemented.
Because SLHCs are not currently
subject to regulatory capital reporting
requirements, the Board is unable to use
reporting information (as was done for
small state member banks) to estimate
capital and risk-weighted assets under
the final rule for small SLHCs.
Therefore, this analysis does not include
an estimation of the capital shortfall for
small SLHCs.
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TABLE 27—PROJECTED NUMBER OF SMALL STATE MEMBER BANKS WITH LESS THAN $500 MILLION IN TOTAL ASSETS A
BASEL III CAPITAL SHORTFALL AND $ AMOUNT OF BASEL III CAPITAL SHORTFALL UNDER THE STANDARDIZED APPROACH, FULLY PHASED-IN
Projected number of state member
banks with Basel III capital shortfall
(fully phased-in)
Projected Basel III capital shortfall
for state member banks
(fully phased-in)
0
0
9
$0
0
11.3
Common Equity Tier 1 to Risk-weighted Assets .............................
Tier 1 to Risk-weighted Assets ........................................................
Minimum Total Capital + Conservation Buffer ................................
As shown in Table 27, the Board
estimates that all small state member
banks that meet the minimum
requirements under the current rules
will meet both the new common equity
tier 1 minimum of 4.5 percent and the
6 percent minimum for tier 1 capital.
The Board estimates that nine small
state member banks will need to
increase capital by a combined $11.3
million by January 1, 2019 in order to
meet the minimum total capital,
including conservation buffer.223
To estimate the cost to small state
member banks of the new capital
requirement, the Board examined the
effect of this requirement on capital
structure and the overall cost of
capital.224 The cost of financing a bank
or any firm is the weighted average cost
of its various financing sources, which
amounts to a weighted average cost of
capital reflecting many different types of
debt and equity financing. Because
interest payments on debt are tax
deductible, a more leveraged capital
structure reduces corporate taxes,
thereby lowering funding costs, and the
weighted average cost of financing tends
to decline as leverage increases. Thus,
an increase in required equity capital
would force a bank to deleverage and—
all else equal—would increase the cost
of capital for that bank.
This increased cost in the most
burdensome year would be tax benefits
foregone: The capital requirement ($11.3
million), multiplied by the interest rate
on the debt displaced and by the
effective marginal tax rate for the banks
affected by the final rule. The effective
marginal corporate tax rate is affected
not only by the statutory federal and
state rates, but also by the probability of
positive earnings and the offsetting
effects of personal taxes on required
bond yields. Graham (2000) considers
these factors and estimates a median
marginal tax benefit of $9.40 per $100
of interest. Using an estimated interest
rate on debt of 6 percent, the Board
estimated that the annual tax benefits
foregone on $11.3 million of capital
switching from debt to equity is
approximately $6,391 per year ($1.08
million * 0.06 (interest rate) * 0.094
(median marginal tax savings)).225 On
average, the cost is approximately $710
per small state member bank per
year.226
As shown in Table 28, the Board also
estimated that the cost of implementing
the creditworthiness in the final rule
will be approximately $27.3 million for
small state member banks. For the nine
small state member banks that also have
to raise additional capital, the Board
estimates that the cost of the final rule
will be approximately $43,710. For all
other small state member banks, the
Board estimated the cost of the final rule
as $43,000 per institution.227
TABLE 28—ESTIMATED COSTS OF CREDITWORTHINESS MEASUREMENT ACTIVITIES FOR STATE MEMBER BANKS WITH
LESS THAN $500 MILLION IN TOTAL ASSETS
Institution
Number of
institutions
Estimated hours
per institution
Estimated cost per
institution
Estimated cost
Small state member banks (assets < $500 million) ................
636
505
$42,925
$27,300,300
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Because the Board has followed
phased-in approach to reporting
requirements for savings and loan
holding companies, the Board does not
possess the same detailed financial
information on small savings and loan
holding companies as it possesses
regarding other small banking
organizations. The Board, however,
sought comment on the potential impact
of the proposed requirements on small
savings and loan holding companies.
Several commenters expressed concern
that the Federal Reserve’s Small Bank
Holding Company Policy Statement
does not apply to savings and loan
holding companies with total
consolidated assets less than $500
million. These commenters noted that
small savings and loan holding
companies presently do not have capital
structures that would allow them to
comply with the requirements of the
Basel III proposal and requested that the
Small Bank Holding Company Policy
exemption be extended to small savings
and loan holding companies.
223 The Board estimates that under the Small
Business Administration’s prior $175 million asset
threshold, all small state member banks that meet
the minimum requirements under the current rules
will meet both the new common equity tier 1
minimum of 4.5 percent and the 6 percent
minimum for tier 1 capital. The Board estimates
that two small state member banks will need to
increase capital by a combined $1.08 million by
January 1, 2019 in order to meet the minimum total
capital, including conservation buffer.
224 See Merton H. Miller, (1995), ‘‘Do the M & M
propositions apply to banks?’’ Journal of Banking &
Finance, Vol. 19, pp. 483–489.
225 See John R. Graham, (2000), How Big Are the
Tax Benefits of Debt?, Journal of Finance, Vol. 55,
No. 5, pp. 1901–1941. Graham points out that
ignoring the offsetting effects of personal taxes
would increase the median marginal tax rate to
$31.5 per $100 of interest.
226 The Board estimates that under the Small
Business Administration’s prior $175 million asset
threshold, that the annual tax benefits foregone on
$1.08 million of capital switching from debt to
equity is approximately $610 per year ($1.08
million * 0.06 (interest rate) * 0.094 (median
marginal tax savings)). On average, the cost is
approximately $305 per small state member bank
per year under the $175 million threshold.
227 The Board estimates that under the Small
Business Administration’s prior $175 million asset
threshold, the cost of implementing the
creditworthiness in the final rule will be
approximately $15.8 million for small state member
banks (369 institutions * $42,925 cost per
institution). For the two small state member banks
that also have to raise additional capital, the Board
estimates that the cost of the final rule will be
approximately $43,305. For all other small state
member banks, the Board estimated the cost of the
final rule as $43,000 per institution.
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For small savings and loan holding
companies, the compliance burdens
described above may be greater than for
those of other covered small banking
organizations. Small savings and loan
holding companies previously have not
been subject to regulatory capital
requirements and reporting
requirements tied regulatory capital
requirements. Small savings and loan
holding companies may therefore need
to invest additional resources in
establishing internal systems (including
purchasing software or hiring new
personnel or training existing
personnel) or raising capital to achieve
compliance with the new minimum
capital requirements and avoid
restrictions on distributions of capital
and discretionary bonus payments the
requirements of the final rule.
Covered small banking organizations
that would have to raise additional
capital to comply with the requirements
of the proposals may incur certain costs,
including costs associated with issuance
of regulatory capital instruments. The
agencies have sought to minimize the
burden of raising additional capital by
providing for transitional arrangements
that phase-in the new capital
requirements over several years,
allowing banking organizations time to
accumulate additional capital through
retained earnings as well as raising
capital in the market. While the final
rule establishes a narrower definition of
regulatory capital—in the form of a
minimum common equity tier 1 capital
ratio, a higher minimum tier 1 capital
ratio, and more stringent limitations on
and deductions from capital—the vast
majority of capital instruments currently
held by small covered banking
organizations, such as common stock
and noncumulative perpetual preferred
stock, would remain eligible as
regulatory capital instruments under the
proposed requirements.
OCC
To estimate the cost of capital needed
to comply with the final rule, the OCC
estimated common equity tier 1, tier 1,
and total risk-based capital as defined
under the more stringent eligibility
standards for capital instruments. The
OCC also adjusted risk-weighted assets
for each banking organization to
estimate the impact of compliance with
the changes under final rule and then
compared each banking organization’s
risk-based capital ratios to the higher
minimums required under the final rule.
If a banking organization’s new measure
of capital under the final rule would not
meet the minimums required for
‘‘adequately-capitalized’’ under the final
rule, the OCC considered that difference
to be a ‘‘shortfall’’, or the amount of
capital that a banking organization
would need to raise in order to comply
with the rule.228
To estimate each national bank or
federal savings association’s capital riskbased capital ratios under the final rule,
the OCC used currently available data
from the quarterly Call Reports. The
OCC arrived at estimates of the new
numerators of the capital ratios by
combining various regulatory reporting
items to reflect definitional changes to
common equity tier 1 capital, tier 1
capital, and total capital as described in
the final rule. The capital ratio
denominator, risk-weighted assets, will
also change under the final rule. The
uniqueness of each institution’s asset
portfolio will cause the direction and
extent of the change in the denominator
to vary from institution to institution.
The OCC, however, was able to arrive at
a reasonable proxy for risk-weighted
assets under the standardized approach
in the final rule by using information
that is in the Call Reports. In particular,
the OCC adjusted foreign exposures,
high volatility commercial real estate,
past-due loans, and securitization
exposures to account for new risk
weights under the final rule.
Using the estimates of the new capital
levels and standardized risk-weighted
assets under the final rule, the OCC
estimated the capital shortfall each
banking organization would encounter
if the rule was fully phased in, as
discussed above.
Table 29 shows the OCC’s estimates of
the number of small national banks and
federal savings associations that would
not meet the minimum capital
requirements according to Call Report
data as of March 31, 2013. Table 30,
which also uses Call Report Data as of
March 31, 2013, shows the projected
Basel III capital shortfalls for those
banking organizations during the final
rule phase-in periods. Because
institutions must simultaneously meet
all of the minimum capital
requirements, the largest shortfall
amount represents our estimate of the
amount of capital small OCC-regulated
banking organizations will need to
accumulate to meet new minimum
capital requirements under the final
rule, fully implemented.
TABLE 29—PROJECTED CUMULATIVE NUMBER OF INSTITUTIONS SHORT OF BASEL III CAPITAL TRANSITION SCHEDULE,
OCC-REGULATED INSTITUTIONS WITH CONSOLIDATED BANKING ASSETS OF $500 MILLION OR LESS, MARCH 31, 2013
Mar. 31, 2013
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Common Equity to
Risk-Weighted
Assets .................
Tier 1 to RiskWeighted Assets
Minimum Total Capital + Conservation Buffer ...........
Jan. 1, 2014
13:14 Oct 10, 2013
Jan. 1, 2016
(PCA)
Jan. 1, 2017
Jan. 1, 2018
Jan. 1, 2019
3
8
13
22
22
22
22
7
14
17
31
31
31
31
23
........................
........................
25
28
33
41
228 The OCC’s analysis assumed that the changes
included in the final rule were on a fully phasedin basis. In addition, for the purposes of this
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for a banking organization that is currently
undercapitalized to meet the current requirements
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TABLE 30—PROJECTED CUMULATIVE BASEL III CAPITAL SHORTFALL, OCC-REGULATED INSTITUTIONS WITH
CONSOLIDATED BANKING ASSETS OF $500 MILLION OR LESS, ($ IN MILLIONS) MARCH 31, 2013
Mar. 31, 2013
Common Equity to
Risk-Weighted
Assets .................
Tier 1 to RiskWeighted Assets
Minimum Total Capital + Conservation Buffer ...........
Jan. 1, 2014
Jan. 1, 2015
Jan. 1, 2016
(PCA)
Jan. 1, 2017
Jan. 1, 2018
Jan. 1, 2019
$13.0
$33.1
$40.0
$84.9
$84.9
$84.9
$84.9
20.9
45.5
56.5
114.9
114.9
114.9
114.9
67.3
........................
........................
86.7
102.9
134.0
163.6
The OCC estimates that 41 small
national banks and federal savings
associations will need to increase
capital by a combined $163.6 million by
January 1, 2019 in order to meet the
minimum total capital, including
conservation buffer.229
To estimate the cost to small national
banks and federal savings associations
of the new capital requirement, the OCC
examined the effect of this requirement
on capital structure and the overall cost
of capital.230 The cost of financing a
bank or any firm is the weighted average
cost of its various financing sources,
which amounts to a weighted average
cost of capital reflecting many different
types of debt and equity financing.
Because interest payments on debt are
tax deductible, a more leveraged capital
structure reduces corporate taxes,
thereby lowering funding costs, and the
weighted average cost of financing tends
to decline as leverage increases. Thus,
an increase in required equity capital
would force a bank to deleverage and—
all else equal—would increase the cost
of capital for that bank.
This increased cost in the most
burdensome year would be tax benefits
foregone: The capital requirement
($163.6 million), multiplied by the
interest rate on the debt displaced and
by the effective marginal tax rate for the
banks affected by the final rule. The
effective marginal corporate tax rate is
affected not only by the statutory federal
and state rates, but also by the
probability of positive earnings and the
offsetting effects of personal taxes on
required bond yields. Graham (2000)
considers these factors and estimates a
median marginal tax benefit of $9.40 per
$100 of interest. Using an estimated
interest rate on debt of 6 percent, the
OCC estimated that the annual tax
benefits foregone on $163.6 million of
capital switching from debt to equity is
approximately $0.9 million per year
($163.6 million * 0.06 (interest rate) *
0.094 (median marginal tax savings)).231
On average, the cost is approximately
$22,500 per small national bank and
federal savings association per year.232
As shown in Table 31, the OCC also
estimated that the cost of implementing
the creditworthiness in the final rule
will be approximately $55.4 million for
small national banks and federal savings
associations ($43,00 per small OCCregulated institution). For the 41 small
state national banks and federal savings
associations that also have to raise
additional capital, the OCC estimates
that the cost of the final rule will be
approximately $65,500. For all other
small national banks and federal savings
associations, the OCC estimated the cost
of the final rule as $43,000 per
institution.233
TABLE 31—ESTIMATED COSTS OF CREDITWORTHINESS MEASUREMENT ACTIVITIES, OCC-REGULATED INSTITUTIONS WITH
CONSOLIDATED BANKING ASSETS OF $500 MILLION OR LESS, MARCH 31, 2013
Institution
Number of OCCregulated
institutions
Estimated hours
per institution
Estimated cost per
institution
Estimated cost
Small national banks and federal savings associations ..........
1,291
505
$42,925
$55,416,175
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To determine if the final rule has a
significant economic impact on small
entities the OCC compared the
estimated annual cost with annual
noninterest expense and annual salaries
and employee benefits for each OCC-
regulated small entity. If the estimated
annual cost is greater than or equal to
2.5 percent of total noninterest expense
or 5 percent of annual salaries and
employee benefits, the OCC classifies
the impact as significant. The OCC
estimates that the final rule will have a
significant economic impact on 240
small OCC-regulated entities using the
$500 million threshold. Following the
same procedure, the final rule will have
a significant economic impact on 219
229 The OCC estimates that under the Small
Business Administration’s prior $175 million asset
threshold, 21 small OCC-regulated institutions will
need to increase capital by a combined $54.1
million by January 1, 2019, in order to meet the
minimum total capital, including conservation
buffer.
230 See Merton H. Miller, (1995), ‘‘Do the M & M
propositions apply to banks?’’ Journal of Banking &
Finance, Vol. 19, pp. 483–489.
231 See John R. Graham, (2000), How Big Are the
Tax Benefits of Debt?, Journal of Finance, Vol. 55,
No. 5, pp. 1901–1941. Graham points out that
ignoring the offsetting effects of personal taxes
would increase the median marginal tax rate to
$31.5 per $100 of interest.
232 The OCC estimates that under the Small
Business Administration’s prior $175 million asset
threshold, 21 small OCC-regulated institutions will
need to increase capital by a combined $54.1
million by January 1, 2019. The OCC estimates that
the cost of lost tax benefits associated with
increasing total capital by $54.1 million will be
approximately $0.3 million per year ($54.1 million
* 0.06 (interest rate) * 0.094 (median marginal tax
savings)). On average, the cost is approximately
$14,500 per institution per year under the $175
million threshold.
233 The OCC estimates that under the Small
Business Administration’s prior $175 million asset
threshold, the cost of implementing the
creditworthiness in the final rule will be
approximately $31.6 million for small national
banks and federal savings associations (737
institutions * $42,925 cost per institution). For the
41 small national banks and federal savings
associations that also have to raise additional
capital, the OCC estimates that the cost of the final
rule will be approximately $57,500. For all other
small national banks and federal savings
associations, the OCC estimated the cost of the final
rule as $43,000 per institution.
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small OCC-regulated entities using the
$175 million threshold. Accordingly,
using five percent as the threshold for
a substantial number of small entities,
the OCC finds that under either SBA
size threshold, the final rule will have
a significant economic impact on a
substantial number of small entities.
F. Steps Taken To Minimize the
Economic Impact on Small Entities;
Significant Alternatives
In response to commenters’ concerns
about the potential implementation
burden on small banking organizations,
the agencies have made several
significant revisions to the proposals for
purposes of the final rule, as discussed
above. Under the final rule, nonadvanced approaches banking
organizations will be permitted to elect
to exclude amounts reported as AOCI
when calculating regulatory capital, to
the same extent currently permitted
under the general risk-based capital
rules.234 In addition, for purposes of
calculating risk-weighted assets under
the standardized approach, the agencies
are not adopting the proposed treatment
for 1–4 family residential mortgages,
which would have required banking
organizations to categorize residential
mortgage loans into one of two
categories based on certain underwriting
standards and product features, and
then risk weight each loan based on its
loan-to-value ratio. The agencies also
are retaining the 120-day safe harbor
from recourse treatment for loans
transferred pursuant to an early default
provision. The agencies believe that
these changes will meaningfully reduce
the compliance burden of the final rule
for small banking organizations. For
instance, in contrast to the proposal, the
final rule does not require banking
organizations to review existing
mortgage loan files, purchase new
software to track loan-to-value ratios,
train employees on the new risk-weight
methodology, or hold more capital for
exposures that would have been deemed
category 2 under the proposed rule,
removing the proposed distinction
between risk weights for category 1 and
2 residential mortgage exposures.
Similarly, the option to elect to retain
the current treatment of AOCI will
reduce the burden associated with
managing the volatility in regulatory
capital resulting from changes in the
value of a banking organization’s AFS
debt securities portfolio due to shifting
234 For most non-advanced approaches banking
organizations, this will be a one-time only election.
However, in certain limited circumstances, such as
a merger of organizations that have made different
elections, the primary Federal supervisory may
permit the resultant entity to make a new election.
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interest rate environments.
Additionally, the final rule grandfathers
the regulatory capital treatment of trust
preferred securities issued by certain
small banking organizations prior to
May 19, 2010, as permitted by section
171 of the Dodd-Frank Act, to reduce
the amount of capital small banking
organizations must raise to comply with
the final rule. These modifications to
the proposed rule should substantially
reduce compliance burden for small
banking organizations.
This Supplementary Information
section includes statements of factual,
policy, and legal reasons for selecting
alternatives adopted in this final rule
and why each one of the other
significant alternatives to the final rule
considered by the agencies and which
affect small entities was rejected.
XVII. Paperwork Reduction Act
In accordance with the requirements
of the Paperwork Reduction Act (PRA)
of 1995 (44 U.S.C. 3501–3521), the
agencies may not conduct or sponsor,
and the respondent is not required to
respond to, an information collection
unless it displays a currently valid
Office of Management and Budget
(OMB) control number.
In conjunction with the proposed
rules, the OCC and FDIC submitted the
information collection requirements
contained therein to OMB for review. In
response, OMB filed comments with the
OCC and FDIC in accordance with 5
CFR 1320.11(c) withholding PRA
approval and instructing that the
collection should be resubmitted to
OMB at the final rule stage. As
instructed by OMB, the information
collection requirements contained in
this final rule have been submitted by
the OCC and FDIC to OMB for review
under the PRA, under OMB Control
Nos. 1557–0234 and 3064–0153. In
accordance with the PRA (44 U.S.C.
3506; 5 CFR part 1320, Appendix A.1),
the Board has reviewed the final rule
under the authority delegated by OMB.
The Board’s OMB Control No. is 7100–
0313.
The final rule contains information
collection requirements subject to the
PRA. They are found in sections l.3,
l.22, l.35, l.37, l.41, l.42, l.62,
l.63 (including tables), l.121 through
l.124, l.132, l.141, l.142, l.153,
l.173 (including tables). The
information collection requirements
contained in sections l.203 through
l.212 concerning market risk are
approved by OMB under Control Nos.
1557–0247, 7100–0314, and 3064–0178.
A total of nine comments were
received concerning paperwork. Seven
expressed concern regarding the
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increase in paperwork resulting from
the rule. They addressed the concept of
paperwork generally and not within the
context of the PRA.
One comment addressed cost,
competitiveness, and qualitative impact
statements, and noted the lack of cost
estimates. It was unclear whether the
commenter was referring to cost
estimates for regulatory burden, which
are included in the preamble to the rule,
or cost estimates regarding the PRA
burden, which are included in the
submissions (information collection
requests) made to OMB by the agencies
regarding the final rule. All of the
agencies’ submissions are publicly
available at www.reginfo.gov.
One commenter seemed to indicate
that the agencies’ and the FDIC’s burden
estimates are overstated. The
commenter stated that, for their
institution, the PRA burden will parallel
that of interest rate risk (240 hours per
year). The agencies’ estimates far exceed
that figure, so no change to the estimates
would be necessary. The agencies’
continue to believe that their estimates
are reasonable averages that are not
overstated.
The agencies have an ongoing interest
in your comments. Comments are
invited on:
(a) Whether the collection of
information is necessary for the proper
performance of the agencies’ functions,
including whether the information has
practical utility;
(b) The accuracy of the estimates of
the burden of the information
collection, including the validity of the
methodology and assumptions used;
(c) Ways to enhance the quality,
utility, and clarity of the information to
be collected;
(d) Ways to minimize the burden of
the information collection on
respondents, including through the use
of automated collection techniques or
other forms of information technology;
and
(e) Estimates of capital or start-up
costs and costs of operation,
maintenance, and purchase of services
to provide information.
XVIII. Plain Language
Section 722 of the Gramm-LeachBliley Act requires the Federal banking
agencies to use plain language in all
proposed and rules published after
January 1, 2000. The agencies have
sought to present the proposed rule in
a simple and straightforward manner
and did not receive any comments on
the use of plain language.
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XIX. OCC Unfunded Mandates Reform
Act of 1995 Determinations
l.3
Section 202 of the Unfunded
Mandates Reform Act of 1995 (UMRA)
(2 U.S.C. 1532 et seq.) requires that an
agency prepare a written statement
before promulgating a rule that includes
a Federal mandate that may result in the
expenditure by State, local, and Tribal
governments, in the aggregate, or by the
private sector of $100 million or more
(adjusted annually for inflation) in any
one year. If a written statement is
required, the UMRA (2 U.S.C. 1535) also
requires an agency to identify and
consider a reasonable number of
regulatory alternatives before
promulgating a rule and from those
alternatives, either select the least
costly, most cost-effective or least
burdensome alternative that achieves
the objectives of the rule, or provide a
statement with the rule explaining why
such an option was not chosen.
Under this rule, the changes to
minimum capital requirements include
a new common equity tier 1 capital
ratio, a higher minimum tier 1 capital
ratio, a supplementary leverage ratio for
advanced approaches banks, new
thresholds for prompt corrective action
purposes, a new capital conservation
buffer, and a new countercyclical
capital buffer for advanced approaches
banks. To estimate the impact of this
rule on bank capital needs, the OCC
estimated the amount of capital banks
will need to raise to meet the new
minimum standards relative to the
amount of capital they currently hold.
To estimate new capital ratios and
requirements, the OCC used currently
available data from banks’ quarterly
Consolidated Reports of Condition and
Income (Call Reports) to approximate
capital under the proposed rule. Most
banks have raised their capital levels
well above the existing minimum
requirements and, after comparing
existing levels with the proposed new
requirements, the OCC has determined
that its proposed rule will not result in
expenditures by State, local, and Tribal
governments, or by the private sector, of
$100 million or more. Accordingly, the
UMRA does not require that a written
statement accompany this rule.
Subpart B—Capital Ratio Requirements and
Buffers
l.10 Minimum capital requirements.
l.11 Capital conservation buffer and
countercyclical capital buffer amount.
l.12 through l.19 [RESERVED]
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Text of Common Rule
Part [ll]—CAPITAL ADEQUACY OF
[BANK]s
Sec.
Subpart A—General Provisions
l.1 Purpose, applicability, reservations of
authority, and timing.
l.2 Definitions.
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Operational requirements for certain
exposures.
l.4 through l.9 [RESERVED]
Subpart C—Definition of Capital
l.20 Capital components and eligibility
criteria for regulatory capital
instruments.
l.21 Minority interest.
l.22 Regulatory capital adjustments and
deductions.
l.23 through l.29 [RESERVED]
Subpart D—Risk-weighted Assets—
Standardized Approach
l.30 Applicability.
Risk-Weighted Assets for General Credit
Risk
l.31 Mechanics for calculating riskweighted assets for general credit risk.
l.32 General risk weights.
l.33 Off-balance sheet exposures.
l.34 OTC derivative contracts.
l.35 Cleared transactions.
l.36 Guarantees and credit derivatives:
Substitution treatment.
l.37 Collateralized transactions.
Risk-Weighted Assets for Unsettled
Transactions
l.38 Unsettled transactions.
l.39 through l.40 [RESERVED]
Risk-Weighted Assets for Securitization
Exposures
l.41 Operational requirements for
securitization exposures.
l.42 Risk-weighted assets for
securitization exposures.
l.43 Simplified supervisory formula
approach (SSFA) and the gross-up
approach.
l.44 Securitization exposures to which
the SSFA and gross-up approach do not
apply.
l.45 Recognition of credit risk mitigants
for securitization exposures.
l.46 through l.50 [RESERVED]
Risk-Weighted Assets for Equity Exposures
l.51 Introduction and exposure
measurement.
l.52 Simple risk-weight approach
(SRWA).
l.53 Equity exposures to investment
funds.
l.54 through l.60 [RESERVED]
Disclosures
l.61 Purpose and scope.
l.62 Disclosure requirements.
l.63 Disclosures by [BANK]s described in
§ l.61.
l.64 through l.99 [RESERVED]
Subpart E—Risk-Weighted Assets—Internal
Ratings-Based and Advanced Measurement
Approaches
l.100 Purpose, applicability, and
principle of conservatism.
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l.101 Definitions.
l.102 through l.120
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[RESERVED]
Qualification
l.121 Qualification process.
l.122 Qualification requirements.
l.123 Ongoing qualification.
l.124 Merger and acquisition transitional
arrangements.
l.125 through l.130 [RESERVED]
Risk-Weighted Assets For General Credit
Risk
l.131 Mechanics for calculating total
wholesale and retail risk-weighted
assets.
l.132 Counterparty credit risk of repo-style
transactions, eligible margin loans, and
OTC derivative contracts.
l.133 Cleared transactions.
l.134 Guarantees and credit derivatives:
PD substitution and LGD adjustment
approaches.
l.135 Guarantees and credit derivatives:
Double default treatment.
l.136 Unsettled transactions.
l.137 through l.140 [RESERVED]
Risk-Weighted Assets for Securitization
Exposures
l.141 Operational criteria for recognizing
the transfer of risk.
l.142 Risk-weighted assets for
securitization exposures.
l.143 Supervisory formula approach
(SFA).
l.144 Simplified supervisory formula
approach (SSFA).
l.145 Recognition of credit risk mitigants
for securitization exposures.
l.146 through l.150 [RESERVED]
Risk-Weighted Assets For Equity Exposures
l.151 Introduction and exposure
measurement.
l.152 Simple risk weight approach
(SRWA).
l.153 Internal models approach (IMA).
l.154 Equity exposures to investment
funds.
l.155 Equity derivative contracts.
l.166 through l.160 [RESERVED]
Risk-Weighted Assets For Operational Risk
l.161 Qualification requirements for
incorporation of operational risk
mitigants.
l.162 Mechanics of risk-weighted asset
calculation.
l.163 through l.170 [RESERVED]
Disclosures
l.171 Purpose and scope.
l.172 Disclosure requirements.
l.173 Disclosures by certain advanced
approaches [BANKS].
l.174 through l.200 [RESERVED]
Subpart F—Risk-weighted Assets—Market
Risk
l.201 Purpose, applicability, and
reservation of authority.
l.202 Definitions.
l.203 Requirements for application of this
subpart F.
l.204 Measure for market risk.
l.205 VaR-based measure.
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l.206 Stressed VaR-based measure.
l.207 Specific risk.
l.208 Incremental risk.
l.209 Comprehensive risk.
l.210 Standardized measurement method
for specific risk.
l.211 Simplified supervisory formula
approach (SSFA).
l.212 Market risk disclosures.
l.213 through l.299 [RESERVED]
Subpart G—Transition Provisions
l.300 Transitions.
Subpart A—General Provisions
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§ l.1 Purpose, applicability, reservations
of authority, and timing.
(a) Purpose. This [PART] establishes
minimum capital requirements and
overall capital adequacy standards for
[BANK]s. This [PART] includes
methodologies for calculating minimum
capital requirements, public disclosure
requirements related to the capital
requirements, and transition provisions
for the application of this [PART].
(b) Limitation of authority. Nothing in
this [PART] shall be read to limit the
authority of the [AGENCY] to take
action under other provisions of law,
including action to address unsafe or
unsound practices or conditions,
deficient capital levels, or violations of
law or regulation, under section 8 of the
Federal Deposit Insurance Act.
(c) Applicability. Subject to the
requirements in paragraphs (d) and (f) of
this section:
(1) Minimum capital requirements
and overall capital adequacy standards.
Each [BANK] must calculate its
minimum capital requirements and
meet the overall capital adequacy
standards in subpart B of this part.
(2) Regulatory capital. Each [BANK]
must calculate its regulatory capital in
accordance with subpart C of this part.
(3) Risk-weighted assets. (i) Each
[BANK] must use the methodologies in
subpart D of this part (and subpart F of
this part for a market risk [BANK]) to
calculate standardized total riskweighted assets.
(ii) Each advanced approaches
[BANK] must use the methodologies in
subpart E (and subpart F of this part for
a market risk [BANK]) to calculate
advanced approaches total riskweighted assets.
(4) Disclosures. (i) Except for an
advanced approaches [BANK] that is
making public disclosures pursuant to
the requirements in subpart E of this
part, each [BANK] with total
consolidated assets of $50 billion or
more must make the public disclosures
described in subpart D of this part.
(ii) Each market risk [BANK] must
make the public disclosures described
in subpart F of this part.
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(iii) Each advanced approaches
[BANK] must make the public
disclosures described in subpart E of
this part.
(d) Reservation of authority. (1)
Additional capital in the aggregate. The
[AGENCY] may require a [BANK] to
hold an amount of regulatory capital
greater than otherwise required under
this part if the [AGENCY] determines
that the [BANK]’s capital requirements
under this part are not commensurate
with the [BANK]’s credit, market,
operational, or other risks.
(2) Regulatory capital elements. (i) If
the [AGENCY] determines that a
particular common equity tier 1,
additional tier 1, or tier 2 capital
element has characteristics or terms that
diminish its ability to absorb losses, or
otherwise present safety and soundness
concerns, the [AGENCY] may require
the [BANK] to exclude all or a portion
of such element from common equity
tier 1 capital, additional tier 1 capital,
or tier 2 capital, as appropriate.
(ii) Notwithstanding the criteria for
regulatory capital instruments set forth
in subpart C of this part, the [AGENCY]
may find that a capital element may be
included in a [BANK]’s common equity
tier 1 capital, additional tier 1 capital,
or tier 2 capital on a permanent or
temporary basis consistent with the loss
absorption capacity of the element and
in accordance with § l.20(e).
(3) Risk-weighted asset amounts. If
the [AGENCY] determines that the riskweighted asset amount calculated under
this part by the [BANK] for one or more
exposures is not commensurate with the
risks associated with those exposures,
the [AGENCY] may require the [BANK]
to assign a different risk-weighted asset
amount to the exposure(s) or to deduct
the amount of the exposure(s) from its
regulatory capital.
(4) Total leverage. If the [AGENCY]
determines that the leverage exposure
amount, or the amount reflected in the
[BANK]’s reported average total
consolidated assets, for an on- or offbalance sheet exposure calculated by a
[BANK] under § l.10 is inappropriate
for the exposure(s) or the circumstances
of the [BANK], the [AGENCY] may
require the [BANK] to adjust this
exposure amount in the numerator and
the denominator for purposes of the
leverage ratio calculations.
(5) Consolidation of certain
exposures. The [AGENCY] may
determine that the risk-based capital
treatment for an exposure or the
treatment provided to an entity that is
not consolidated on the [BANK]’s
balance sheet is not commensurate with
the risk of the exposure and the
relationship of the [BANK] to the entity.
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Upon making this determination, the
[AGENCY] may require the [BANK] to
treat the exposure or entity as if it were
consolidated on the balance sheet of the
[BANK] for purposes of determining the
[BANK]’s risk-based capital
requirements and calculating the
[BANK]’s risk-based capital ratios
accordingly. The [AGENCY] will look to
the substance of, and risk associated
with, the transaction, as well as other
relevant factors the [AGENCY] deems
appropriate in determining whether to
require such treatment.
(6) Other reservation of authority.
With respect to any deduction or
limitation required under this part, the
[AGENCY] may require a different
deduction or limitation, provided that
such alternative deduction or limitation
is commensurate with the [BANK]’s risk
and consistent with safety and
soundness.
(e) Notice and response procedures.
In making a determination under this
section, the [AGENCY] will apply notice
and response procedures in the same
manner as the notice and response
procedures in [12 CFR 3.404, (OCC); 12
CFR 263.202 (Board)].
(f) Timing. (1) Subject to the transition
provisions in subpart G of this part, an
advanced approaches [BANK] that is not
a savings and loan holding company
must:
(i) Except as described in paragraph
(f)(1)(ii) of this section, beginning on
January 1, 2014, calculate advanced
approaches total risk-weighted assets in
accordance with subpart E and, if
applicable, subpart F of this part and,
beginning on January 1, 2015, calculate
standardized total risk-weighted assets
in accordance with subpart D and, if
applicable, subpart F of this part;
(ii) From January 1, 2014 to December
31, 2014:
(A) Calculate risk-weighted assets in
accordance with the general risk-based
capital rules under [12 CFR part 3,
appendix A and, if applicable, appendix
B (national banks), or 12 CFR part 167
(Federal savings associations) (OCC); 12
CFR parts 208 or 225, appendix A, and,
if applicable, appendix E (state member
banks or bank holding companies,
respectively) (Board)] 1 and substitute
1 For the purpose of calculating its general riskbased capital ratios from January 1, 2014 to
December 31, 2014, an advanced approaches
[BANK] shall adjust, as appropriate, its riskweighted asset measure (as that amount is
calculated under [12 CFR part 3, appendix A, Sec.
3 and, if applicable, 12 CFR part 3, appendix B
(national banks), or 12 CFR part 167 (Federal
savings associations) (OCC); 12 CFR parts 208 and
225, and, if applicable, appendix E (state member
banks or bank holding companies, respectively)
(Board)] in the general risk-based capital rules) by
excluding those assets that are deducted from its
regulatory capital under § l.22.
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such risk-weighted assets for
standardized total risk-weighted assets
for purposes of § l.10;
(B) If applicable, calculate general
market risk equivalent assets in
accordance with [12 CFR part 3,
appendix B, section 4(a)(3) (national
banks) (OCC); 12 CFR parts 208 or 225,
appendix E, section 4(a)(3) (state
member banks or bank holding
companies, respectively) (Board); and
12 CFR part 325, appendix C, section
4(a)(3) (state nonmember banks and
state savings associations)] and
substitute such general market risk
equivalent assets for standardized
market risk-weighted assets for purposes
of § l.20(d)(3); and
(C) Substitute the corresponding
provision or provisions of [12 CFR part
3, appendix A, and, if applicable,
appendix B (national banks), or 12 CFR
part 167 (Federal savings associations)
(OCC)); 12 CFR parts 208 or 225,
appendix A, and, if applicable,
appendix E (state member banks or bank
holding companies, respectively)
(Board)] for any reference to subpart D
of this part in: § l.121(c); § l.124(a)
and (b); § l.144(b); § l.154(c) and (d);
§ l.202(b) (definition of covered
position in paragraph (b)(3)(iv)); and
§ l.211(b);2
(iii) Beginning on January 1, 2014,
calculate and maintain minimum
capital ratios in accordance with
subparts A, B, and C of this part,
provided, however, that such [BANK]
must:
(A) From January 1, 2014 to December
31, 2014, maintain a minimu