Alert November 13, 2012

Federal Banking Agencies Advise Banking Institutions that Effective Date of Revised Regulatory Capital Rules is Expected to be Delayed

The FRB, FDIC and OCC (the “Agencies”) issued a joint release (the “Release”) in which they advised banking institutions that the effective date of the Agencies’ revised regulatory capital rules is expected to be delayed until after January 1, 2013, the effective date stated in the proposed versions of the regulatory capital rules (the “Proposed Rules”).

The Proposed Rules were described in the June 12, 2012 Financial Services Alert. The Agencies said the effective date of the revised regulatory capital rules is being delayed because of the volume and wide range of comments received on the Proposed Rules and that the Agencies “will take operational and other considerations into account when determining appropriate implementation dates and associated transition periods.”