The American Bankers Association joined three other financial trade associations in a comment letter to the FDIC, Federal Reserve and OCC last week seeking additional clarity on the recently issued final rules tailoring the application of enhanced prudential standards and applying capital and standardized liquidity requirements.
Echoing comments made previously by ABA, the groups urged the agencies to clarify that effective date of the rules is Jan. 1, 2020. They also requested timely additional guidance on capital planning and CCAR from the Federal Reserve and called on the agencies to address a number of technical matters related to the final rules.
In addition, the groups made several recommendations, including that the agencies allow U.S. intermediate holding companies to calculate their initial cross-jurisdictional activity indicator using the FR Y-15 filing as of June 30, 2020.
