Notice & Comment

Banking and Financial Services: Federal Regulators’ ANPR on Alternatives to Use of Credit Ratings in Regulatory Capital Guidelines, by Jonathan Rusch

On August 10, the Federal Reserve Board of Governors, the FDIC, the Office of the Comptroller of the Curency, and the Office of Thrift Supervision jointly issued an Advance Notice of Proposed Rulemaking (ANPR) regarding alternatives to the use of credit ratings in the four agencies’ risk-based capital rules for banking organizations. A joint release by the agencies stated that the ANPR “is issued in response to section 939A of the Dodd-Frank Wall Street Reform and Consumer Protection Act (Act), enacted on July 21, 2010, which requires the agencies to review regulations that (1) require an assessment of the credit-worthiness of a security or money market instrument and (2) contain references to or requirements regarding credit ratings. In addition, the agencies are required to remove such references and requirements and substitute in their place uniform standards of credit-worthiness, where feasible.” Comments will be due no later than 60 days after the ANPR is published in the Federal Register.

This post was originally published on the legacy ABA Section of Administrative Law and Regulatory Practice Notice and Comment blog, which merged with the Yale Journal on Regulation Notice and Comment blog in 2015.

Print Friendly, PDF & Email