Dan Ryan is Leader of the Financial Services Advisory Practice at PricewaterhouseCoopers LLP. This post is based on a PwC publication by Mr. Ryan, Mike Alix, Adam Gilbert, and Armen Meyer.
On March 4th, the Federal Reserve Board (FRB) reproposed its single-counterparty credit limits (SCCL) rule. The reproposal comes several years after two earlier versions (in 2011 and 2012), [1] and almost two years after the related large exposures framework issued by the Basel Committee on Banking Supervision (BCBS). [2] It is intended to reduce systemic risk by limiting a large banking organization’s credit exposure to any single counterparty as a percentage of the bank’s capital. The reproposal would apply to large banking organizations with over $50 billion in total consolidated assets, including US bank holding companies (BHCs), intermediate holding companies (IHCs), and foreign banking organizations’ (FBOs) combined US operations. [3]