Posts by Bill Hoisington

REGULATORY DEVELOPMENTS IAIS Global Systemically Important Insurer (G-SII) Designations Coming Soon Since the financial and economic crises, global stability remains at the top of political and regulatory agendas.  New regulatory measures are being considered by individual countries and collectively through international bodies including the G-20 and the Financial Stability Board (FSB).  In the U.S. the…

REGULATORY DEVELOPMENTS Federal Reserve’s New Supervision Framework for Large Financial Institutions On December 17, the Federal Reserve issued a letter that set forth a new framework for the consolidated supervision of large financial institutions.  The framework has two primary objectives: i) enhancing resiliency of a firm to lower the probability of its failure or inability…

REGULATORY DEVELOPMENTS Regulatory Capital Proposals Update On November 9, the federal banking agencies issued guidance indicating that the new regulatory capital rules (commonly referred to as Basel III) are not expected to become effective on January 1, 2013.  That effective date was identified in the proposed rulemakings issued in June. The agencies acknowledged industry concerns…

REGULATORY DEVELOPMENTS Regulatory Capital Proposals (Update) The comment period for the regulatory capital rule proposals ended on October 22nd.  More than a thousand comment letters were submitted to the agencies addressing numerous aspects of the proposals.  As noted in last month’s LRA update, we submitted a comment letter regarding the Standardized Approach NPR.  Our letter…

REGULATORY DEVELOPMENTS Regulatory Capital Proposals Update We continue to review industry comments submitted to and posted by the federal banking agencies on the proposed regulatory capital rules.  To date, there have not been any comments on the proposed rules impact on BOLI.  At the request of clients, we have identified BOLI-specific issues in need of…

REGULATORY DEVELOPMENTS Agencies Extend Comment Period on Regulatory Capital Proposals As reported in the July LRA, the banking agencies issued three notices of proposed rulemaking that would revise and replace the agencies’ current capital rules.  The original comment period was set to expire on September 7, but has been extended to October 22. As proposed,…

REGULATORY DEVELOPMENTS OCC Corporate Decision on BOLI as Capital In a recently released Corporate Decision, the OCC approved a request from a federal savings association (FSA) to treat the cash surrender value of certain BOLI policies as a contribution to capital.  The policies were on the lives of certain officers and were transferred from the…

REGULATORY DEVELOPMENTS Agencies Release Final and Proposed Capital Rules As reported in our 6/13/2012 Ad Hoc LRA, the Office of the Currency of the Comptroller (OCC), Federal Reserve, and the Federal Deposit Insurance Corporation (FDIC) announced the finalization of the market risk capital rules that were proposed in 2011.  While BOLI assets generally do not…

REGULATORY DEVELOPMENTS New Interagency Stress Testing Guidance The Office of the Comptroller of the Currency (OCC), the Federal Reserve and the Federal Deposit Insurance Corporation (FDIC) jointly issued Supervisory Guidance on Stress Testing for Banking Organizations with Total Consolidated Assets of More Than $10 Billion.  The guidance builds upon previously issued supervisory guidance that discusses…

REGULATORY DEVELOPMENTS FSOC Adopts Rules to Identify SIFI Nonbank Financial Companies On April 3, the Financial Stability Oversight Council (FSOC) adopted final rules and interpretative guidance for determining systemically important nonbank financial companies.  Nonbank financial companies include financial guarantors, insurance companies, asset management companies, private equity firms, and hedge funds among others.  Dodd-Frank Section 113…