PROPOSED REGULATORY CAPITAL RULES: STANDARDIZED APPROACH FOR RISK-WEIGHTED ASSETS; MARKET DISCIPLINE AND DISCLOSURE REQUIREMENTS

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.