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Capital and Prudential Standards Blog

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Risk Governance: Visual Memorandum on Final Guidelines Issued by the OCC

The OCC has issued final risk governance guidelines that formalize its heightened expectations for large national banks and federal savings associations. The risk governance guidelines set new, and much higher, minimum standards for the design and implementation of a bank’s own risk governance framework and the oversight of such framework by the bank’s board of directors. The guidelines are enforceable under the OCC’s statutory authority to prescribe operational and managerial standards for national banks and federal savings associations.

State banks that are not subject to the OCC’s risk governance guidelines should still pay attention because the same or similar principles will likely be applied by the Federal Reserve and the FDIC to large state member and non-member banks.…  Read More

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Blackline of Federal Reserve’s Revisions to Capital Planning and Stress Testing Rules

The Federal Reserve has issued a final rule that amends certain aspects of its capital planning and stress testing regulations.  We have prepared a blackline (available here) of the Federal Reserve’s final rule against the proposed rule issued in June 2014.

View Blackline of Federal Reserve’s Revisions to Capital Planning and Stress Testing Rules

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Supplementary Leverage Ratio (SLR): Visual Memorandum

The U.S. banking agencies have finalized revisions to the denominator of the supplementary leverage ratio (SLR), which include a number of key changes and clarifications to their April 2014 proposal. The SLR represents the U.S. implementation of the Basel III leverage ratio. Under the U.S. banking agencies’ SLR framework, advanced approaches firms must maintain a minimum SLR of 3%, while the 8 U.S. bank holding companies that have been identified as global systemically important banks (U.S. G-SIBs) and their U.S. insured depository institution subsidiaries are subject to enhanced SLR standards.…  Read More

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U.S. Basel III Liquidity Coverage Ratio (LCR) Final Rule: Visual Memorandum

The U.S. banking agencies have issued a final rule to implement the Basel III liquidity coverage ratio (LCR) in the United States. The LCR requires large banking organizations to maintain a minimum amount of liquid assets to withstand a 30-day standardized stress scenario. The U.S. LCR final rule is more stringent than the Basel Committee’s LCR framework in several significant respects. In addition, the final rule makes a number of key changes to the proposed rule.

Davis Polk’s visual memorandum uses diagrams, flowcharts, timelines, examples and comparison tables to illustrate key aspects of the U.S.…  Read More

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Fed Governor Tarullo Discusses G-SIB Surcharge Implementation

Today, Federal Reserve Governor Daniel K. Tarullo delivered a speech that, among other things, provided a preview of the forthcoming proposal to implement the GSIB risk-based capital surcharge.

 

While our proposal will use the GSIB risk-based capital surcharge framework developed by the BCBS as a starting point, it will strengthen the BCBS framework in two important respects. First, the surcharge levels for U.S. GSIBs will be higher than the levels required by the BCBS, noticeably so for some firms. Second, the surcharge formula will directly take into account each U.S. Read More

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Blackline of Supplementary Leverage Ratio (SLR) Denominator Final Rule

Today, the U.S. banking agencies issued a final rule regarding the denominator of the Basel III supplementary leverage ratio (SLR).  We have prepared a blackline that compares the text of the final rule against the proposed rule that was issued in April 2014.

View Davis Polk SLR Denominator Final Rule Blackline

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