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Regulatory Capital

​Over the last few years there have been fundamental changes to regulatory capital.  There have been an increasing number of regulatory capital proposals, both domestically and internationally.  These proposals will likely have significant impacts on bank balance sheets and funding costs.

​ABA Position

ABA strongly supports​ ongoing regulatory reform efforts that aim to make financial systems safer and more robust.  This includes supporting improvements to the quality of capital in banks and increasing the risk sensitivity of bank capital requirements in such a way that will enhance the ability of the banking sector to serve customers and promote economic growth.  However, ABA believes that many regulatory capital efforts will not make the financial system safer.




 Regulatory Capital Proposals Open for Comment


Agencies: OCC, FDIC, FRB.
Relevant banks: All with ADC exposures.
Interagency Notice of Proposed Rulemaking adopting the Economic Growth Act’s definition of High Volatility Commercial Real Estate. The proposal asks for comments on certain terms and conditions contained in the revised definitions. Comments due November 28. Primary ABA contacts are Sharon Whitaker and Hugh Carney.


 Comment Letters


 Letters to Congress