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Transmittal Archive

July 2020Transmittal 473 Effective: 7/1/2020
Banks and Banking
Regulation H and Regulation Q
In light of recent disruptions in economic conditions caused by the coronavirus disease 2019 (COVID-19) and strains in U.S. financial markets, the Board, the Federal Deposit Insurance Corporation (FDIC), and the Office of the Comptroller of the Currency (OCC) issued an interim final rule that temporarily revises the supplementary leverage ratio calculation for depository institutions. More... Under the interim final rule, any depository institution subsidiary of a U.S. global systemically important bank holding company or any depository institution subject to Category II or Category III capital standards may elect to exclude temporarily U.S. Treasury securities and deposits at Federal Reserve Banks from the supplementary leverage ratio denominator. Additionally, under this interim final rule, any depository institution making this election must request approval from its primary federal banking regulator prior to making certain capital distributions so long as the exclusion is in effect. The agencies adopted this interim final rule to allow depository institutions that elect to opt into this treatment additional flexibility to act as financial intermediaries during this period of financial disruption. The tier 1 leverage ratio is not affected by this interim final rule. The interim final rule is effective June 1, 2020 (Regulation H and Regulation Q, Docket R-1718), the same day it was published in the Federal Register.
Policy Statements
The Board, the FDIC, the National Credit Union Administration (NCUA), and the OCC issued on June 1, 2020, Interagency Policy Statement on Allowances for Credit Losses, in response to changes in the accounting for credit losses under U.S. generally accepted accounting principles, as promulgated by the Financial Accounting Standards Board. More... The interagency policy statement describes the measurement of expected credit losses using the current expected credit losses (CECL) methodology and updates concepts and practices detailed in existing supervisory guidance that remain applicable. CECL is effective beginning in 2020 for most public financial institutions, and in 2023 for all other institutions. For institutions that have adopted CECL, this interagency policy statement replaces the guidance in SR letter 06-17, Interagency Policy Statement on the Allowance for Loan and Lease Losses (ALLL), and SR letter 01-17, Final Interagency Policy Statement on Allowance for Loan and Lease Losses (ALLL) Methodologies and Documentation for Banks and Savings Institutions (Guidance, Allowance for Loan and Lease Losses at 3-1490).
The Board, the FDIC, the NCUA, and the OCC issued on May 20, 2020, Interagency Lending Principles for Offering Responsible Small-Dollar Loans, to encourage supervised banks, savings associations, and credit unions to offer responsible small-dollar loans to customers for both consumer and small-business purposes (Guidance, Credit Availability at 3-1511.5).
The Board, the FDIC, the NCUA, and the OCC issued on May 11, 2020, Interagency Guidance on Credit Risk Review Systems, which presents principles for establishing a system of independent, ongoing credit risk review in accordance with safety and soundness standards. The guidance replaces the “Loan Review Systems” guidance, which is contained in Attachment 1 of the 2006 Interagency Policy Statement on the Allowance for Loan and Lease Losses (at 3-1480), and is being issued as a standalone document. More... The guidance maintains the general principles enumerated in Attachment 1 and is being finalized generally as proposed, with enhanced language to reinforce the flexibility to tailor the guidance to institutions of different sizes and clarify the applicability of the guidance for retail portfolios (Guidance, Safety and Soundness at 3-1579.291).
Holding and Nonbank Financial Companies
Regulation YY
The Board adopted a final rule to amend the compliance dates related to single-counterparty credit limits for bank holding companies and foreign banking organizations (final SCCL rule). More... The final rule revises the final SCCL rule to modify the initial compliance dates of January 1, 2020, for a foreign banking organization that has the characteristics of a global systemically important banking organization, and July 1, 2020, for any other foreign banking organization subject to the final SCCL rule to July 1, 2021, and January 1, 2022, respectively, regarding the SCCL applicable to a foreign banking organization’s combined U.S. operations only. The final rule is effective May 28, 2020 (Regulation YY, Docket R-1534), the same day it was published in the Federal Register.
Consumer and Community Affairs
CFPB’s Regulation C
The Consumer Financial Protection Bureau (CFPB) is amending Regulation C to increase the threshold for reporting data about closed-end mortgage loans, so that institutions originating fewer than 100 closed-end mortgage loans in either of the two preceding calendar years will not have to report such data effective July 1, 2020. More... The CFPB is also setting the threshold for reporting data about open-end lines of credit at 200 open-end lines of credit effective January 1, 2022, upon the expiration of the current temporary threshold of 500 open-end lines of credit. The final rule is effective July 1, 2020 (Consumer Financial Protection Bureau, Regulation C, Docket CFPB-2019-0021) and was published in the Federal Register on May 12, 2020.
Payment System
Regulation CC
The Board and the CFPB jointly issue regulations under sections 603(d)(1), 604, 605, and 609(a) of the Expedited Funds Availability Act (EFA Act) (12 U.S.C. 4002(d)(1), 4003, 4004, 4008(a)) that are codified within Regulation CC (12 CFR part 229). More... The agencies issued a final rule effective September 3, 2019, to amend Regulation CC to implement a statutory requirement in the EFA Act to adjust the dollar amounts under the EFA Act for inflation. The agencies also amended Regulation CC to incorporate the Economic Growth, Regulatory Relief, and Consumer Protection Act amendments to the EFA Act, which include extending coverage to American Samoa, the Commonwealth of the Northern Mariana Islands, and Guam, and making certain other technical amendments. The final rule’s amendments to sections 229.1, 229.10, 229.11, 229.12(d), 229.21, and appendix E are effective July 1, 2020 (Regulation CC, Docket R-1637) and were published in the Federal Register on July 3, 2019.

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