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Subject: Capital Treatment of Recourse, Direct Credit Substitutes, and Residual Interests in Asset Securitizations
Date: May 23, 2002
To: Chief Executive Officers of All National Banks, Department and Division Heads, All Examining Personnel, and Other Interested Parties
Description: Interpretations of Final Rule
The guidance attached to this bulletin continues to apply to federal savings associations.
The Office of the Comptroller of the Currency, the Federal Deposit Insurance Corporation, the Federal Reserve Board, and the Office of Thrift Supervision published a final rule on the Capital Treatment of Recourse, Direct Credit Substitutes and Residual Interests in Asset Securitizations in November of 2001.1 The rule became effective on January 1, 2002, and has generated several questions from the industry regarding proper implementation and application. This issuance transmits a question-and-answer document that provides interpretive guidance on issues raised by the final rule. Further guidance will be provided, as necessary.
For Further Information
You may contact Amrit Sekhon, risk expert, Capital Policy at (202) 874-5070, or Laura Goldman, senior attorney, Legislative & Regulatory Activities Division at (202) 874-5090 for additional information.
Michael L. Brosnan
1 66 Fed. Reg. 59614 (November 29, 2001).