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OCC BULLETIN 2015-14
To: Chief Executive Officers of All National Banks, Federal Branches and Agencies, and Federal Savings Associations; Department and Division Heads; All Examining Personnel; and Other Interested Parties

Description: Tool for Calculating Capital Requirements Under Simplified Supervisory Formula Approach

Summary

The Office of the Comptroller of the Currency (OCC), the Board of Governors of the Federal Reserve System, and the Federal Deposit Insurance Corporation have developed an automated tool to help national banks and federal savings associations (collectively, banks) calculate risk-based capital requirements for securitization exposures. The agencies are making this tool available for all banks that use the simplified supervisory formula approach to help calculate associated capital requirements. Banks may opt to use the simplified supervisory formula approach under the standardized approach, which is part of the revised capital rule that became effective January 1, 2015. At their discretion, banks may use the tool to help calculate regulatory capital requirements for securitization exposures under the revised capital rule. Use of the tool, however, is not required, nor is it a component of regulatory reporting.

The revised capital rule replaced the existing generally applicable risk-based capital standards with a standardized approach. Banks subject to the advanced approaches risk-based capital rule must use the standardized approach to determine their risk-based capital floor, and all other banks must use the standardized approach to determine their overall minimum risk-based capital requirements.

Among other changes, the standardized approach removes references to external credit ratings (consistent with the Dodd-Frank Wall Street Reform and Consumer Protection Act) and provides alternative measures of creditworthiness for determining risk-based capital requirements for securitization exposures.

Note for Community Banks

This bulletin applies to all banks.

Use of the automated tool is not mandatory. The tool is not a part of the revised capital rule or a component of regulatory reporting. Therefore, banks may use the tool solely at their own discretion.

Highlights

The simplified supervisory formula approach is designed to apply relatively higher risk-based capital requirements to the more risky junior tranches of securitizations, which are the first to absorb losses, and relatively lower requirements to the most senior tranches. The automated tool

  • helps banks calculate risk-based capital for securitization exposures and helps reduce potential burden.
  • requires five inputs to calculate the minimum required risk-based capital for a securitization exposure. The inputs are typically readily available to investors.
  • requires manual inputs consistent with the requirements of the revised capital rule. To ensure that the tool is being used appropriately, banks should continue to reference the revised capital framework when determining regulatory capital requirements.

Additionally, the OCC continues to expect banks to have comprehensive understanding of their securitization exposures and to meet all due diligence requirements. This is consistent with the revised capital rule as well as existing regulations and guidance pertaining to investment activities and safe and sound banking practices.

Further Information

Please contact David Elkes, Risk Expert, Capital Policy, at (202) 640-6370.

 

Jennifer C. Kelly
Senior Deputy Comptroller and Chief National Bank Examiner

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