US Federal Banking Agencies issue Community Bank Leverage Ratio proposal

On November 21, 2018, the Office of the Comptroller of the Currency (the “OCC”), the Board of Governors of the Federal Reserve System (the “Board”), and the Federal Deposit Insurance Corporation (the “FDIC”) (collectively, the “Federal Banking Agencies” or the “Agencies”) jointly issued a notice of proposed rulemaking (the “NPR” or the “Proposal”) that would provide for an optional, simplified measure of capital adequacy for qualifying community banking organizations. The Proposal was issued pursuant to Section 201 of the Economic Growth, Regulatory Relief, and Consumer Protection Act, which Congress passed in May. Under the Proposal, a depository institution or depository institution holding company with less than $10 billion in total consolidated assets would, subject to risk-based qualifying criteria, be deemed a “qualifying community banking organization.” A qualifying community…

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