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Highlights:
The attached statement notes that:
- The Agencies are considering whether it is appropriate and consistent with the provisions of the
Dodd-Frank Act not to subject pooled investment vehicles for TruPS, such as TruPS CDOs, to the
prohibitions on ownership of covered funds in section 619 of the Dodd-Frank Act, in order to
eliminate restrictions that might otherwise have consequences that are inconsistent with the
relief Congress intended to provide community banking organizations under section 171(b)(4)(C) of
the Dodd-Frank Act.
- The Agencies intend to address this matter no later than January 15, 2014.
- The accounting staffs of the agencies believe that, consistent with generally accepted
accounting principles, any actions in January 2014 that occur before the issuance of December 31,
2013, financial reports, including the FR Y-9C and the Call Report, should be considered when
preparing those financial reports.
The FDIC recommends that banking organizations consider this statement of pending regulatory action
and, once it is taken, the action itself when making any accounting or economic decisions related to
their holdings of TruPS CDOs and their treatment under the Volcker Rule.
Distribution:
FDIC-Supervised Banks (Commercial
and Savings) and FDIC-Supervised Savings Associations
Suggested Routing:
Board of Directors
Chief Executive Officer
Chief Financial Officer
Chief Risk Officer
Related Topics:
Dodd-Frank Wall Street Reform and
Consumer Protection Act
Bank Holding Company Act
Attachment:
Statement Regarding Treatment of Certain Collateralized
Debt Obligations Backed by Trust Preferred Securities under the Rules implementing Section 619 of
the Dodd-Frank Act - PDF (PDF Help)
Contact:
Bobby Bean, Associate Director,
Capital Markets Branch, at bbean@fdic.gov or (202) 898-6888
Karl Reitz, Chief, Capital Markets
Strategies, at kreitz@fdic.gov or (202) 898-6888
Michael Spencer, Senior Policy
Analyst, at michspencer@fdic.gov or (202) 898-6888
Note:
FDIC Financial Institution Letters
(FILs) may be accessed from the FDIC's Web site at http://www.fdic.gov/news/news/financial/2013/index.html.
To receive FILs electronically, please visit http://www.fdic.gov/about/subscriptions/fil.html.
Paper copies may be obtained via the FDIC's Public Information Center, 3501 Fairfax Drive, E 1002,
Arlington, VA 22226 (877-275-3342 or 703 562-2200).
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