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Capital Considerations for Bank Securitizers and Investors

July 26, 2013

Summary: On July 2, 2013, the Board of Governors of the Federal Reserve System (the Board) adopted new capital requirements implementing the so-called Basel III standards for domestic banks, federal savings associations and bank and savings and loan holding companies. On July 9, 2013, the Federal Deposit Insurance Corporation and the Office of the Comptroller of the Currency added their approval. These standards apply beginning on January 1, 2014, to banking organizations (other than savings and loan holding companies) that compute their capital using the advanced approaches; they apply beginning on January 1, 2015, to all other covered institutions except bank holding company subsidiaries of non-US banks that are currently relying on the Board’s Supervision and Regulation Letter 01-1, which are not required to comply until July 21, 2015. 

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Karsten Giesecke
Special Counsel
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Henry G. Morriello
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George M. Williams jr
Special Counsel
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