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.
Summary and Blackline of OCC’s Proposed Revisions to National Bank and Federal Savings Association Licensing Rules
We have prepared a summary and blackline (available here) of the OCC’s proposed changes to its rules for national banks and federal savings associations relating to policies and procedures for corporate activities and transactions (“licensing rules”).
Background: The Dodd-Frank Act transferred to the OCC all functions of the former Office of Thrift Supervision (OTS) relating to federal savings associations. With a few exceptions, the OCC currently has one set of rules applicable to national banks and another set of rules applicable to federal savings associations, or, where appropriate, to all savings associations.… Read More
Following is a summary of the Basel Committee’s final framework for measuring, reporting and limiting a bank’s exposures to single counterparties and groups of connected counterparties. The large exposures framework, which relies on a number of concepts in the Basel Committee’s risk-based capital framework, is intended to ensure greater international consistency in regulatory and supervisory approaches to large exposures and to act as a backstop to risk-based capital requirements.
Blackline Showing Changes: Davis Polk’s blackline of the Basel Committee’s April 2014 final vs.… Read More
Davis Polk Blackline of Federal Reserve’s Corrections to Dodd-Frank Stress Test Capital Ratio Projections
Today, the Federal Reserve published corrections to its 2014 supervisory Dodd-Frank Act stress test (“DFAST“) results. We have prepared a blackline (available here) showing the Federal Reserve’s revised capital ratio projections for 30 large U.S. bank holding companies under the supervisory severely adverse stress scenario. According to the Federal Reserve, it adjusted the supervisory DFAST results to “address inconsistencies in the treatment of the fourth quarter 2013 actual capital actions and assumptions about preferred and employee compensation-related issuance over the course of the planning horizon.”
Federal Reserve, Dodd-Frank Act Stress Test 2014: Supervisory Stress Test Methodology and Results (originally published on Mar.… Read More
We have prepared a blackline that compares (1) the U.S. banking agencies’ final supervisory guidance regarding annual Dodd-Frank company-run stress tests for banking organizations with $10 billion to $50 billion in total consolidated assets (mid-sized banking organizations) against (2) the July 2013 proposed supervisory guidance.