OCC and FRB Final Rule Revising Regulatory Capital Requirements Published in Federal Register

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The OCC’s and FRB’s final rule (the “Final Rule”) that revises and replaces their existing risk-based and leverage capital requirements was published in the October 11, 2013 issue of the Federal Register.  The Final Rule is consistent with the parallel interim final regulatory capital rule published by the FDIC.  The revised regulatory capital rules of the FRB, OCC and the FDIC were discussed in the July, 9, 2013 Financial Services Alert.  The Final Rule reflects changes to the regulatory capital rules that are designed to implement provisions of the Dodd-Frank Act and of “the Basel capital framework, including Basel III and other elements.”  Subject to various transition provisions, the Final Rule is effective for banking organizations that use the advanced approaches on January 1, 2014 and for other banking organizations on January 1, 2015.

IRS Circular 230 Disclosure: To ensure compliance with requirements imposed by the IRS, we inform you that any U.S. tax advice contained in this informational piece (including any attachments) is not intended or written to be used, and may not be used, for the purpose of (i) avoiding penalties under the Internal Revenue Code or (ii) promoting, marketing or recommending to another party any transaction or matter addressed herein.

DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

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