OCC Updates Accounting Guidance

On December 12th, the Office of the Comptroller of the Currency (“OCC”) released an update to the Bank Accounting Advisory Series (“BAAS”). The BAAS covers a variety of topics and promotes consistent application of accounting standards among national banks and federal savings associations. The update includes recent answers to frequently asked questions from the industry and examiners covering areas such as acquired loans, allowance for loan and lease losses, other real estate owned, and other borrowings. OCC Press Release.

Federal Reserve Board Proposes Capital Surcharge for Largest Banks

On December 9th, the Federal Reserve Board published a proposed rule that would establish a methodology to identify whether a U.S. bank holding company is a global systemically important banking organization (“GSIB”). A firm identified as a GSIB would be subject to a risk-based capital surcharge that is calibrated based on its systemic risk profile. Failure to maintain the capital surcharge would subject the GSIB to restrictions on capital distributions and discretionary bonus payments. The proposal would be phased in beginning on January 1, 2016, becoming fully effective on January 1, 2019. Comments should be submitted on or before February 28, 2015. Federal Reserve Board Press Release.

Federal Reserve Board Proposes Capital Surcharge for Largest Banks

On December 9th, the Federal Reserve Board published a proposed rule that would establish a methodology to identify whether a U.S. bank holding company is a global systemically important banking organization (“GSIB”). A firm identified as a GSIB would be subject to a risk-based capital surcharge that is calibrated based on its systemic risk profile. Failure to maintain the capital surcharge would subject the GSIB to restrictions on capital distributions and discretionary bonus payments. The proposal would be phased in beginning on January 1, 2016, becoming fully effective on January 1, 2019. Comments should be submitted on or before February 28, 2015. Federal Reserve Board Press Release.