On August 8, 2012, the banking regulators (Federal Reserve, OCC, and FDIC) extended the comment period on the three notices of proposed rulemaking that implement the Basel III capital standards and revised risk-weighting rules. Many organizations representing community banks had requested more time for community banks to analyze the impact of those proposed rules on their operations, and the regulatory agencies have responded to those requests.
The deadline for submitting comments is now October 22, 2012 (comments had been due on September 7, 2012). We recommend that community banks carefully analyze the impact of the proposals on their balance sheets and business plans and submit comments as appropriate. These comments are key in the effort to effect change in the final rules. We have heard from many bankers that they are concerned about the new rules’ impact on a wide variety of facets of their banks, including mortgage lending, real estate lending, and the structure of their securities portfolios.
Please contact any member of the Bryan Cave financial institutions team if you would like to discuss the impact of the rules on your bank or if you need help drafting your comment letter.