The Clearing House (TCH) submitted a comment letter to the banking agencies on their proposal to simplify the regulatory capital rules. In the letter, TCH generally supports the agencies’ efforts to simplify the regulatory capital rules and to address concerns with the definition of high volatility commercial real estate (HVCRE) exposure. However, TCH believes that certain aspects of the proposal require modifications and the agencies should make other revisions to the capital rules. TCH argues that the agencies should: (i) revise the proposed definition of high volatility acquisition, development, or construction (HVADC) exposure and the manner of its implementation; (ii) apply all aspects of the proposal to the standardized approach calculations of all firms; (iii) allow advanced approaches firms to opt out of recognizing unrealized gains and losses on HQLA in regulatory capital; and (iv) reconsider the proposed limitations on the inclusion of minority interest in capital.
You Might Also Be Interested In...
Bank Capital and Stress Testing
U.S. Bank Capital Levels: Aligning With or Exceeding Midpoint Estimates of Optimal
Basel Finalization
BPI’s Greg Baer Testifies on Basel Endgame Before House Financial Services Subcommittee
Basel Finalization
New BPI Ad Campaign Encourages Americans to Demand Accountability from Regulators for Higher Loan Prices
More Posts by This Author
Bank Capital and Stress Testing
U.S. Bank Capital Levels: Aligning With or Exceeding Midpoint Estimates of Optimal
Central Bank Digital Currency
BPI’s Paige Pidano Paridon Testifies on CBDC Before House Subcommittee
Bank Activities and Structure
BPI Statement Before the U.S. House Financial Services Committee’s Subcommittee on Digital Assets, Financial Technology and Inclusion
Bank Activities and Structure
BPI Statement Before the U.S. House Financial Services Committee’s Subcommittee on Financial Institutions and Monetary Policy