MBA Letter to the Banking Agencies on Basel III Re-proposal Recommendations
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MBA comments on the notices of proposed rulemaking (the “NPRs”) issued by the Board of Governors of the Federal Reserve System (the “Board”), the Federal Deposit Insurance Corporation (the “FDIC”), and the Office of the Comptroller of the Currency (the “OCC”) (collectively, the “Agencies”). The NPRs consist of (i) proposed revisions to the risk-based capital framework for Category I and II banking organizations (the “Basel III Proposal”) and (ii) proposed modifications to the standardized approach for credit risk applicable to other banking organizations (the “Standardized Approach Proposal,” and together with the Basel III Proposal, the “Proposals”).
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