Highlights:
- The proposal would modify the general risk-based and advanced risk-based capital adequacy
frameworks to eliminate the exclusion of certain consolidated asset-backed commercial paper
programs from risk-weighted assets.
- The proposal would provide a reservation of authority in the general risk-based and advanced
risk-based capital adequacy frameworks to permit the agencies to require banking organizations
to treat entities that are not consolidated under accounting standards as if they were
consolidated for risk-based capital purposes.
- The agencies request public comment on the regulatory capital impact of FAS 166 and 167,
including, with respect to the types of VIEs a bank will have to consolidate, the features and
characteristics of securitization transactions or other transactions with VIEs that are more or
less likely to cause a bank to provide implicit support, and the effect of FAS 166 and 167 on a
bank's financial position, lending, and activities.
- The agencies also request public comment on a phase-in period, and the impact of FAS 166 and 167
on loan loss provisioning, mortgage loan modifications, and securitization reform programs.
Distribution:
FDIC-Supervised Banks (Commercial and Savings)
Suggested Routing:
Chief Executive Officer
Chief Financial Officer
Chief Risk Officer
Related Topics:
Risk-Based Capital Rules
12 CFR Part 325
Attachments:
Contact:
James Weinberger, Sr. Policy Analyst, at
jweinberger@fdic.gov or (202) 898-7034
Robert Storch, Chief Accountant, at
rstorch@fdic.gov or (202) 898-8906
Mark Handzlik, Senior Attorney, at
mhandzlik@fdic.gov or (202) 898-3990
Note:
FDIC financial institution letters (FILs) may be
accessed from the FDIC's Web site at
www.fdic.gov/news/news/financial/2009/index.html.
To receive FILs electronically, please visit
http://www.fdic.gov/about/subscriptions/fil.html.
Paper copies of FDIC financial institution letters
may be obtained through the FDIC's Public
Information Center, 3501 Fairfax Drive, E-1002,
Arlington, VA 22226 (1-877-275-3342 or 703-562-
2200).
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