- 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.
FDIC-Supervised Banks (Commercial and Savings)
Chief Executive Officer
Chief Financial Officer
Chief Risk Officer
Risk-Based Capital Rules
12 CFR Part 325
James Weinberger, Sr. Policy Analyst, at
email@example.com or (202) 898-7034
Robert Storch, Chief Accountant, at
firstname.lastname@example.org or (202) 898-8906
Mark Handzlik, Senior Attorney, at
email@example.com or (202) 898-3990
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-