​OCC Revises Subordinated Debt Guidance, Sample Notes

The OCC on Friday released revised and reorganized guidance for subordinated debt issued by national banks and federal savings associations. The guidelines apply to all subordinated debt regardless of whether it is included in regulatory capital.

The agency also issued two sample subordinated notes for national banks, one providing sample language for a note included in tier 2 capital and one for a note not included in tier 2 capital. These sample notes apply only to national banks; there is no preexisting sample note for thrifts, the OCC added. The new guidelines and sample notes took effect for sub debt issued on or after Friday.