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Financial Institution Letter

Regulatory Capital Standards Advance Notice of Proposed Rulemaking Regarding Alternatives to the Use of External Credit Ratings in Risk-Based Capital Guidelines of the Federal Banking Agencies

Summary: The FDIC and the other federal banking agencies are requesting comment on alternative standards of creditworthiness to replace the use of credit ratings in the risk-based capital requirements. The comment period for the attached Advance Notice of Proposed Rulemaking (ANPR) will be 60 days after its publication in the Federal Register. 


  • The Dodd-Frank Wall Street Reform and Consumer Protection Act requires the FDIC and the other federal banking agencies to review regulations that require an assessment of the creditworthiness of a security or money market instrument and contain references to or requirements regarding credit ratings. The agencies also are required to remove such requirements that refer to or rely on credit ratings and substitute in their place uniform standards of creditworthiness.
  • This ANPR seeks comment on standards of creditworthiness, other than credit ratings, that may be used in the agencies' risk-based capital rules.
  • Commenters' views are solicited on the feasibility of implementing the alternative approaches included in this ANPR and any other methodologies.

FDIC-Supervised Banks (Commercial and Savings) 

Suggested Routing: 
Chief Executive Officer 
Chief Financial Officer 
Chief Accounting Officer 

FDIC financial institution letters (FILs) may be accessed from the FDIC's Web site at

To receive FILs electronically, please visit

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). 

Additional Related Topics

  • Risk-Based Capital Rules
  • 12 CFR Part 325
Last Updated: August 16, 2010