FDIC Seeks Comments on Renewal of Certain Information Collections

The information collection on credit risk retention impacts insured state non-member banks, insured state branches of foreign banks, state savings associations, and certain subsidiaries of these entities. This information collection request relates to the disclosure and recordkeeping requirements of 12 CFR part 373 (the Credit Risk Retention Rule), which implements section 15G of the Securities Exchange Act of 1934, added by section 941 of the Dodd-Frank Act. The Credit Risk Retention Rule was jointly issued by FDIC, OCC, FED, SEC and, with respect to the portions of the Rule addressing the securitization of residential mortgages, FHFA and the Department of Housing and Urban Development.

The information collection on disclosure requirements associated with the supplementary leverage ratio impacts insured state nonmember banks and state savings associations that are subject to the FDIC advanced approaches risk-based capital rules. The supplementary leverage ratio regulations strengthen the definition of total leverage exposure and improve the measure of a banking organization's on- and off-balance sheet exposures. The rules are generally consistent with the 2014 BCBS revisions and promote consistency in the calculation of this ratio across jurisdictions. 

The information collection on interagency supervisory guidance for the supervisory review process of capital adequacy (Pillar 2) related to the implementation of the Basel II advanced capital framework impacts insured state nonmember banks and certain subsidiaries of these entities. As part of the supervisory guidance, banks should state clearly the definition of capital used in any aspect of its internal capital adequacy assessment process (ICAAP) and document any changes in the internal definition of capital. Additionally, the board of directors are required approve the ICAAP of a bank, review it on a regular basis, and approve any changes. The number of institutions subject to the record keeping requirements has decreased from eight to two.

FDIC invites comments on:

• Whether the collections of information are necessary for the proper performance of FDIC's functions, including whether the information has practical utility
• The accuracy of the estimates of the burdens of the information collections, including the validity of the methodology and assumptions used
• Ways to enhance the quality, utility, and clarity of the information to be collected
• Ways to minimize the burden of the collections of information on respondents, including through the use of automated collection techniques or other forms of information technology
  

Related Link: Federal Register Notice

Comment Due Date: July 24, 2018

Keywords: Americas, US, Banking, Credit Risk Retention, Credit Risk, Dodd Frank Act, SLR, Disclosures, ICAAP, Reporting, FDIC