Alert January 04, 2011

Interagency Proposal to Set Risk-Based Capital Floor for Large Financial Institutions Published in the Federal Register

The OCC, FRB and FDIC published a Joint Notice of Proposed Rulemaking titled “Risk-Based Capital Standards: Advanced Capital Adequacy Framework-Basel II; Establishment of a Risk-Based Capital Floor” in the Federal Register on December 30, 2010 (the “NPR”).  The NPR would amend the advanced risk-based capital adequacy standards to be consistent with certain provisions of the Collins Amendment of the Dodd-Frank Act, and would amend the general risk-based capital rules to provide limited flexibility consistent with the Collins Amendment for recognizing the relative risk of certain assets generally not held by depository institutions.  For details regarding the NPR, please see the December 21, 2010 Alert.  Comments on the NPR must be received by February 28, 2011.