The Harvard Law School Forum on Corporate Governance https://corpgov.law.harvard.edu The leading online blog in the fields of corporate governance and financial regulation. Mon, 20 Jul 2026 20:07:07 +0000 en-US hourly 1 https://wordpress.org/?v=6.5.8 https://corpgov.law.harvard.edu/wp-content/uploads/2024/02/cropped-photography-4-e1706898544564-1-32x32.png Federal Reserve Proposes Revised Bank Capital Rules – The Harvard Law School Forum on Corporate Governance https://corpgov.law.harvard.edu 32 32 Federal Reserve Proposes Revised Bank Capital Rules https://corpgov.law.harvard.edu/2012/06/12/federal-reserve-proposes-revised-bank-capital-rules/?utm_source=rss&utm_medium=rss&utm_campaign=federal-reserve-proposes-revised-bank-capital-rules https://corpgov.law.harvard.edu/2012/06/12/federal-reserve-proposes-revised-bank-capital-rules/#comments Tue, 12 Jun 2012 13:22:32 +0000 http://blogs.law.harvard.edu/corpgov/?p=29761?d=20150113142219EST Posted by H. Rodgin Cohen, Sullivan & Cromwell LLP, on Tuesday, June 12, 2012
Editor's Note:

H. Rodgin Cohen is partner and senior chairman of Sullivan & Cromwell LLP focusing on acquisition, corporate governance, regulatory and securities law matters. This post is based on a Sullivan & Cromwell LLP publication. A chart from Luigi De Ghenghi and Andrew Fei of Davis Polk & Wardwell LLP explaining implementation of the Basel III rules is available here.

Recently, the Board of Governors of the Federal Reserve System (the “FRB”) approved for publication three notices of proposed rulemaking (the “NPRs”) substantially amending the risk-based capital rules for banks. [1] The FRB also approved final amendments to the market risk rules (the “Market Risk Amendments”), often referred to as “Basel II.5”. [2] The NPRs and Market Risk Amendments are meant to be joint rulemakings with the Office of the Comptroller of the Currency (the “OCC”) and the Federal Deposit Insurance Corporation (the “FDIC” and, together with the OCC and the Federal Reserve the “Agencies”) and will be published in the Federal Register after approval by the OCC and the FDIC, which is expected during the next several weeks.

The changes to the Agencies’ capital rules proposed in the NPRs and finalized in the Market Risk Amendments when implemented, taken together, will represent the most substantial revisions to the Agencies’ capital rules since the adoption in 1989 of risk-based capital standards based on the Basel Committee on Banking Supervision’s (“BCBS”) 1988 Accord, known as “Basel I”. Among other things:

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