Welcome to the Davis Polk Capital and Prudential Standards blog. This blog is created by the lawyers in the bank regulatory practice of Davis Polk’s Financial Institutions Group. Its goal is to provide a central resource for the many ongoing regulatory changes that are reshaping bank capital and prudential requirements in the United States and abroad. We expect to post about key developments on an ongoing basis, and will include related Davis Polk memoranda, analysis, visuals, comparisons and other helpful materials whenever available.… Read More
Federal Reserve Advises Large Banking Organizations to Carefully Evaluate Certain Risk-Transfer Transactions
Today, the Federal Reserve issued a Supervision and Regulation letter (SR letter) entitled Risk Transfer Considerations When Assessing Capital Adequacy – Supplemental Guidance on Consolidated Supervision Framework for Large Financial Institutions.
The SR letter applies to U.S. bank holding companies and savings and loan holding companies with consolidated assets of $50 billion or more as well as foreign banking organizations with combined assets of U.S. operations of $50 billion or more (collectively, “large banking organizations”).
The purpose of the SR letter is to provide guidance on how certain risk transfer transactions affect assessments of capital adequacy at large banking organizations. … Read More
Today, the Basel Committee finalized its revised risk-based capital framework for a bank’s equity investments in funds, which was proposed in July 2013. The revised framework includes three approaches for calculating risk-based capital requirements for equity investments in funds (hierarchy of approaches), which are in decreasing order of risk-sensitivity.
Scope of Application: The revised framework is applicable to banks’ equity investments in all types of funds that are held in their banking book, including off-balance sheet exposures (e.g., unfunded commitments to subscribe to a fund’s future capital calls). … Read More
Today, the Federal Reserve issued a final rule that makes technical changes to the market risk capital rule to align it with the U.S. Basel III capital framework adopted by the Federal Reserve earlier this year.
The market risk capital rule is used by banking organizations with significant trading activities to calculate regulatory capital requirements for market risk. The technical changes to the rule reflect modifications by the Organization for Economic Cooperation and Development regarding country risk classifications. The revisions also clarify the criteria for determining whether underlying assets are delinquent for certain securitization positions in the trading book. … Read More
Financial Stability Board Updates List of Global Systemically Important Banks (G-SIBs); Basel Committee Releases Data Relating to Methodology for Identifying G-SIBs
Today, the Financial Stability Board (FSB) published its annual update to the list of global systemically important banks (G-SIBs). The updated list is based on 2012 data and the revised assessment methodology for identifying G-SIBs issued by the Basel Committee in July 2013. Please see below for a blackline of the 2013 list of G-SIBs against the 2012 list.
Data relating to G-SIB Assessment Methodology for Identifying G-SIBs: In its revised assessment methodology for identifying G-SIBs, the Basel Committee announced that it will bring forward by one year to November 2013 the publication of the denominators used to calculate banks’ G-SIB scores, as well as the cut-off score and thresholds used to identify G-SIBs and allocate them to different G-SIB capital surcharge buckets. … Read More
Yesterday, the Federal Reserve issued instructions for the 2014 Comprehensive Capital Analysis and Review (CCAR). Thirty bank holding companies with $50 billion or more of total consolidated assets will participate in the 2014 CCAR, including 18 bank holding companies that participated in the 2013 CCAR and 12 bank holding companies that will participate in CCAR for the first time.
We have created a blackline that compares the Federal Reserve’s 2014 CCAR instruction with its 2013 instructions.