In June 2012, regulators issued three notices of proposed rulemaking that would revise and replace the current capital rules with the Basel III regime. We submitted a comment letter seeking several clarifications on the treatment of BOLI under the Standardized Approach framework. The letter covered a range of topics including treatment of general account assets and questions on the application of the look-through approaches for separate account policies.
In summary, our comment letter recommended that the regulators add Investment Fund Exposure line items that are similar to lines within the Advanced Approach RWA forms. If that recommendation was not deemed viable, we suggested that the regulators provide additional guidance regarding how BOLI programs should be reflected in the RWA schedule.