August 28, 2018

FED issued an interim final rule expanding the applicability of its small bank holding company policy statement, as required by the Economic Growth, Regulatory Relief, and Consumer Protection Act (EGRRCP Act) of 2018. The interim final rule raises the statement's asset threshold from USD 1 billion to USD 3 billion in total consolidated assets. This interim final rule takes effect on publication in the Federal Register and comments will be accepted for 30 days after publication.

The policy statement facilitates the transfer of ownership of small community banks by allowing their holding companies to operate with higher levels of debt than would normally be permitted. While holding companies that meet the conditions of the policy statement are excluded from consolidated capital requirements, their depository institutions continue to be subject to minimum capital requirements. The statement also applies to savings and loan holding companies with less than USD 3 billion in total consolidated assets. The changes in this rule also impact certain regulatory reporting requirements. 

FED is modifying, effective immediately, the respondent panel for the FR Y-9SP, FR Y-9C, and FR Y-9LP for bank holding companies and savings and loan holding companies with USD 1 billion or more but less than USD 3 billion in consolidated assets, to align the threshold in the Policy Statement. If these institutions meet the qualitative requirements, they will not be required to file the FR Y-9C and the FR Y-9LP (including regulatory capital information) and would instead file the FR Y-9SP. These changes would be consistent with the final rule’s changes to the Policy Statement and will reduce the regulatory reporting burden for these smaller institutions. Since most bank holding companies and savings and loan holding companies with less than USD 3 billion in consolidated assets have limited activities outside of their subsidiary banks, FED believes that relying on summary parent-only financials from the FR Y-9SP and detailed depository institution financials from the Consolidated Reports of Condition and Income (FFIEC 031, FFIEC 041, FFIEC 051; OMB No. 7100-0036)) is sufficient for supervisory purposes.

 

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Comment Due Date: FR + 30 Days

Keywords: Americas, US, Banking, Small BHCs, EGRRCP Act, Reporting, Policy Statement, Proportionality, FED

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