News & Analysis as of

Banking Agencies Adopt Supplementary Leverage Ratio Final Rule

On September 3, the Federal Reserve Board, the Federal Deposit Insurance Corporation and the Office of the Comptroller of the Currency adopted a final rule modifying the definition of the denominator of the supplementary...more

FDIC Issues Guidance on Basel III Capital Conservation Buffer for Subchapter S Banks

A recent Financial Institution Letter provides guidance on the FDIC’s methodology when entertaining requests from banks or savings associations organized as Subchapter S corporations (S-corporation banks) to pay dividends to...more

Basel Committee on Banking Supervision Publishes Consultative Document on Guidelines Concerning Weak Banks

On June 18, the Basel Committee on Banking Supervision (BCBS) published a consultative document on supervisory guidelines for identifying and dealing with weak banks. The guidelines are intended to assist bank supervisors and...more

Be Careful What You Wish For

Many community bankers have looked surprised at the “internationalization” of our banking rules. Standards coming out of the Basel Committee, particularly the Basel III Capital Rules, do not seem to fit community banks. The...more

Basel III Framework: Large Exposures

Even banks with strong capital ratios may fail as a result of the sudden failure of a counterparty or group of connected counterparties. To address this risk and to complement the now near-final Basel III framework, the Basel...more

Basel Committee Issues Final Rules on Measuring and Controlling Large Exposures

On April 15, 2013, the Basel Committee on Banking Supervision (the “Basel Committee”) issued final rules (the “Final Rules”) concerning the supervisory framework for measuring and controlling large exposures, setting tighter...more

Updated Basel III Monitoring Workbook Published

The Bank for International Settlements has published on its website an updated version of the Basel Committee on Banking Supervision’s Basel III monitoring workbook, accompanying instructions and a list of frequently asked...more

Basel III Framework: The Leverage Ratio

Reducing excess “leverage” in the banking sector is a key component of the Basel III capital standards. “Leverage” for these purposes means the ratio between a bank’s non-risk-weighted assets and its capital. The ratio is...more

What next for the Basel III leverage ratio framework?

Financial Services analysis: Following the publication of Basel III's leverage ratio framework and disclosure requirements, Peter Green, partner at Morrison & Foerster, analyses the likely impact of the guidance and how it...more

Federal Reserve Board Proposes Stricter Bank Liquidity Rules

Proposed rules include a shorter transition period, a narrower definition of what qualifies as “high quality liquid assets,” and a more stringent liquidity stress-testing methodology than the framework issued by the Basel...more

Dodd-Frank: The Liquidity Proposal Is Issued

The three Federal bank regulatory agencies have reached agreement on the terms of a proposed regulation that, for the first time, would impose quantitative requirements on major US banks’ liquidity management practices. The...more

BASEL III Lite: Regulators Adjust Capital Rules For Community Banks

The three Federal bank regulatory agencies (the “Agencies”) have adopted new capital regulations implementing the first portion of the international principles, known as “Basel III,” agreed in the Basel Committee on Banking...more

Banking Agencies Issue Final Basel III Capital Regulations

A new regulatory capital framework for US banks has been introduced by the issuance on July 2 of final capital regulations (the Final Regulation) for bank holding companies and state-chartered member banks by the Board of...more

Basel III Implementation in the U.S.

On July 2, the Fed finalized a rule to implement Basel III in the U.S. ...more

Federal Reserve Approves Final Regulatory Capital Rules

On July 2, the Federal Reserve Board approved a final rule to implement the risk-based and leverage capital requirements in the Basel III framework and relevant provisions mandated by the Dodd-Frank Act. ...more

Federal Bank Regulators Adopt Final Basel III Capital Rules

On July 2, 2013, the Federal Reserve Board, and on July 9, 2013, the FDIC and OCC, adopted a final rule that implements the "Basel III" changes to the international regulatory capital framework and revises the U.S. risk-based...more

Capital Is Contagious— The FDIC and OCC Approve Final Risk-based Capital Rules, and the Agencies Propose a Supplemental Leverage...

Today, July 9, the Federal Deposit Insurance Corporation (“FDIC”) and the Office of the Comptroller of the Currency (“OCC”) took two significant actions on the implementation of new regulatory capital requirements in the U.S....more

They’re Here: The Final Interagency Regulatory Capital Rules

The Federal Reserve Board today approved the publication of the long-awaited final regulatory capital rules (“Final Rules” ), which were proposed one year ago (the “Proposed Rules”). While today’s action was taken by the...more

Federal Reserve Adopts Basel III for U.S. Banks

On July 2, 2013, the Federal Reserve Board approved a final rule implementing the Basel III regulatory capital reforms from the Basel Committee on Banking Supervision as well as certain changes required by the Dodd-Frank Wall...more

More Leverage for the Unleveraged—Basel Committee Proposes Specific Leverage Capital Framework for Banking Organizations

On June 26, the Basel Committee on Banking Supervision (“Basel Committee”) published a Consultative Document that proposes specific leverage capital requirements, and related disclosure requirements (the “Proposal”), that...more

Basel Developments: A Renewed Focus on Credit Risk Mitigation Transactions and Regulatory Capital Arbitrage

Transactions that reduce regulatory capital requirements for banks have recently come under media and regulatory scrutiny. The New York Times characterized them as a “trading sleight of hand.” The Basel Committee on Banking...more

Financial Services Legislative And Regulatory Update -- February 25‚ 2013

In This Issue: Leading the Past Week; Legislative Branch; Executive Branch; and Upcoming Hearings. Excerpt from Leading the Past Week - With both the House and Senate on recess this past week, the President...more

Basel Committee on Banking Supervision Endorses Revised Basel III Liquidity Standards for Banks

It was announced on January 6, that the Basel Committee on Banking Supervision’s (BCBS) Group of Governors and Heads of Supervision (GHOS) has endorsed revised Basel III liquidity standards for banks....more

Orrick's Financial Industry Week in Review - January 7, 2013

In This Issue: *Financial Industry Developments - OCC Guidance on Transition Periods under Section 716 of the Dodd-Frank Act - CFTC Reporting of Swap Transactions and Swap Dealer Registration - Department...more

Liquidity Coverage Ratio: New Basel Measurement Published

On January 6, 2013, the Group of Governors and Heads of Supervision (“GHOS”), which oversees the Basel Committee on Banking Supervision (“BCBS”), approved a significantly revised version of the liquidity coverage ratio...more

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