Differences in Capital and Accounting Standards Among the Federal Banking and Thrift Agencies; Report to Congressional Committees

FEDERAL DEPOSIT INSURANCE CORPORATION

Differences in Capital and Accounting Standards Among the Federal

Banking and Thrift Agencies; Report to Congressional Committees

AGENCY: Federal Deposit Insurance Corporation (FDIC).

ACTION: Report to the Committee on Banking and Financial Services of

the U.S. House of Representatives and to the Committee on Banking,

Housing, and Urban Affairs of the United States Senate Regarding

Differences in Capital and Accounting Standards Among the Federal

Banking and Thrift Agencies.

SUMMARY: This report has been prepared by the FDIC pursuant to Section

37(c) of the Federal Deposit Insurance Act (12 U.S.C. 1831n(c)).

Section 37(c) requires each federal banking agency to report to the

Committee on Banking and Financial Services of the House of

Representatives and to the Committee on Banking, Housing, and Urban

Affairs of the Senate any differences between any accounting or capital

standard used by such agency and any accounting or capital standard

used by any other such agency. The report must also contain an

explanation of the reasons for any discrepancy in such accounting and

capital standards and must be published in the Federal Register.

FOR FURTHER INFORMATION CONTACT: Robert F. Storch, Chief, Accounting

Section, Division of Supervision, Federal Deposit Insurance

Corporation, 550 17th Street, NW., Washington, D.C. 20429, telephone

(202) 898-8906.

SUPPLEMENTARY INFORMATION: The text of the report follows:

Report to the Committee on Banking and Financial Services of the

U.S. House of Representatives and to the Committee on Banking,

Housing, and Urban Affairs of the United States Senate Regarding

Differences in Capital and Accounting Standards Among the Federal

Banking and Thrift Agencies

A. Introduction

This report has been prepared by the Federal Deposit Insurance

Corporation (FDIC) pursuant to Section 37(c) of the Federal Deposit

Insurance Act, which requires the agency to submit a report to

specified Congressional Committees describing any differences in

regulatory

[[Page 20634]]

capital and accounting standards among the federal banking and thrift

agencies, including an explanation of the reasons for these

differences. Section 37(c) also requires the FDIC to publish this

report in the Federal Register. This report covers differences existing

during 1997 and developments affecting these differences.

The FDIC, the Board of Governors of the Federal Reserve System

(FRB), and the Office of the Comptroller of the Currency (OCC)

(hereafter, the banking agencies) have substantially similar leverage

and risk-based capital standards. While the Office of Thrift

Supervision (OTS) employs a regulatory capital framework that also

includes leverage and risk-based capital requirements, it differs in

several respects from that of the banking agencies. Nevertheless, the

agencies view the leverage and risk-based capital requirements as

minimum standards and most institutions are expected to operate with

capital levels well above the minimums, particularly those institutions

that are expanding or experiencing unusual or high levels of risk.

The banking agencies, under the auspices of the Federal Financial

Institutions Examination Council (FFIEC), have developed uniform

Reports of Condition and Income (Call Reports) for all commercial banks

and FDIC-supervised savings banks. Effective with the March 31, 1997,

report date, the FFIEC and the banking agencies adopted generally

accepted accounting principles (GAAP) as the reporting basis for the

balance sheet, income statement, and related schedules in the Call

Report. Prior to 1997, the reporting standards for the bank Call Report

were substantially consistent with GAAP. In the limited number of cases

where the bank Call Report standards differed from GAAP, the regulatory

reporting requirements were intended to be more conservative than GAAP.

Adopting GAAP as the reporting basis for recognition and measurement

purposes in the basic schedules of the Call Report was designed to

eliminate these differences, thereby producing greater consistency in

the information collected in bank Call Reports and general purpose

financial statements and reducing regulatory burden.

The OTS requires each savings association to file the Thrift

Financial Report (TFR), the reporting standards for which are

consistent with GAAP. Thus, through year-end 1996, the reporting

standards applicable to the bank Call Report differed in some respects

from the reporting standards applicable to the TFR. However, with the

banking agencies' move to GAAP for Call Report purposes in 1997, the

most significant differences in reporting standards among the agencies

that were cited in previous reports have been eliminated.1

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\1\ In the following areas, differences in reporting standards

between the banking agencies and the OTS were eliminated in 1997:

sales of assets with recourse, futures and forward contracts, excess

servicing fees, offsetting of assets and liabilities, and in-

substance defeasance of debt.

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Section 303 of the Riegle Community Development and Regulatory

Improvement Act of 1994 (12 U.S.C. 4803) requires the banking agencies

and the OTS to conduct a systematic review of their regulations and

written policies in order to improve efficiency, reduce unnecessary

costs, and eliminate inconsistencies. It also directs the four agencies

to work jointly to make uniform all regulations and guidelines

implementing common statutory or supervisory policies. The results of

these efforts must be ``consistent with the principles of safety and

soundness, statutory law and policy, and the public interest.'' The

four agencies' efforts to eliminate existing differences among their

regulatory capital standards as part of the Section 303 review are

discussed in the following section.

B. Differences in Capital Standards Among the Federal Banking and

Thrift Agencies

B.1. Minimum Leverage Capital

The banking agencies have established leverage capital standards

based upon the definition of Tier 1 (or core) capital contained in

their risk-based capital standards. These standards require the most

highly-rated banks (i.e., those with a composite rating of ``1'' under

the Uniform Financial Institutions Rating System (UFIRS)) to maintain a

minimum leverage capital ratio of at least 3 percent if they are not

anticipating or experiencing any significant growth and meet certain

other conditions. All other banks must maintain a minimum leverage

capital ratio that is at least 100 to 200 basis points above this

minimum (i.e., an absolute minimum leverage ratio of not less than 4

percent).

The OTS has a 3 percent core capital and a 1.5 percent tangible

capital leverage requirement for savings associations. However, the

OTS' Prompt Corrective Action rule requires a savings association to

have a 4 percent leverage capital ratio (or a 3 percent leverage

capital ratio if it is rated a composite ``1'' under the UFIRS) in

order for the association to be considered ``adequately capitalized.''

Consequently, the 4 percent leverage capital ratio is, in effect, the

controlling leverage capital standard for savings associations other

than those rated a composite ``1.''

As a result of the agencies' Section 303 review of their regulatory

capital standards, the agencies issued a proposal for public comment on

October 27, 1997, that, among other provisions, would establish a

uniform leverage requirement. As proposed, institutions rated a

composite 1 under the Uniform Financial Institutions Rating System

would be subject to a minimum 3 percent leverage ratio and all other

institutions would be subject to a minimum 4 percent leverage ratio.

This change would simplify and streamline the agencies' leverage rules

and make them uniform. The comment period for the proposal ended on

December 26, 1997.

B.2. Interest Rate Risk

Section 305 of the Federal Deposit Insurance Corporation

Improvement Act of 1991 mandates that the agencies' risk-based capital

standards take adequate account of interest rate risk. In August 1995,

each of the banking agencies amended its capital standards to

specifically include an assessment of a bank's interest rate risk, as

measured by its exposure to declines in the economic value of its

capital due to changes in interest rates, in the evaluation of bank

capital adequacy. In June 1996, the banking agencies issued a Joint

Agency Policy Statement on Interest Rate Risk which provides guidance

on sound practices for managing interest rate risk. This policy

statement does not establish a standardized measure of interest rate

risk nor does it create an explicit capital charge for interest rate

risk. Instead, the policy statement identifies the standards that the

banking agencies will use to evaluate the adequacy and effectiveness of

a bank's interest rate risk management.

In 1993, the OTS adopted a final rule which adds an interest rate

risk component to its risk-based capital standards. Under this rule,

savings associations with a greater than normal interest rate exposure

must take a deduction from the total capital available to meet their

risk-based capital requirement. The deduction is equal to one half of

the difference between the institution's actual measured exposure and

the normal level of exposure. The OTS has partially implemented this

rule by formalizing the review of interest rate risk; however, no

deductions from capital are being made. As described above, the

approach adopted by the banking agencies differs from that of the OTS.

[[Page 20635]]

B.3. Subsidiaries

The banking agencies generally consolidate all significant

majority-owned subsidiaries of the parent bank for regulatory capital

purposes. The purpose of this practice is to assure that capital

requirements are related to all of the risks to which the bank is

exposed. For subsidiaries which are not consolidated on a line-for-line

basis, their balance sheets may be consolidated on a pro-rata basis,

bank investments in such subsidiaries may be deducted entirely from

capital, or the investments may be risk-weighted at 100 percent,

depending upon the circumstances. These options for handling

subsidiaries for purposes of determining the capital adequacy of the

parent bank provide the banking agencies with the flexibility necessary

to ensure that institutions maintain capital levels that are

commensurate with the actual risks involved.

Under the OTS' capital guidelines, a statutorily mandated

distinction is drawn between subsidiaries engaged in activities that

are permissible for national banks and subsidiaries engaged in

``impermissible'' activities for national banks. For regulatory capital

purposes, subsidiaries of savings associations that engage only in

permissible activities are consolidated on a line-for-line basis, if

majority-owned, and on a pro rata basis, if ownership is between 5

percent and 50 percent. For subsidiaries that engage in impermissible

activities, investments in, and loans to, such subsidiaries are

deducted from assets and capital when determining the capital adequacy

of the parent.

B.4. Servicing Assets and Intangible Assets

The banking agencies' rules permit mortgage servicing assets and

purchased credit card relationships to count toward capital

requirements, subject to certain limits. These two categories of assets

are in the aggregate limited to 50 percent of Tier 1 capital. In

addition, purchased credit card relationships alone are restricted to

no more than 25 percent of an institution's Tier 1 capital. Any

mortgage servicing assets and purchased credit card relationships that

exceed these limits, as well as all other intangible assets such as

goodwill and core deposit intangibles, are deducted from capital and

assets in calculating an institution's Tier 1 capital.

The OTS's capital treatment of servicing assets and intangible

assets is generally consistent with the banking agencies' rules.

However, the OTS rule grandfathers core deposit intangibles acquired

before February 1994 up to 25 percent of core capital and all purchased

mortgage servicing rights acquired before February 1990.

B.5. Capital Requirements for Recourse Arrangements

B.5.a. Leverage Capital Requirements--With certain exceptions, the

banking agencies required full leverage capital charges on assets sold

with recourse through December 31, 1996. This leverage capital

treatment applied to most assets sold with recourse because the banking

agencies' pre-1997 regulatory reporting rules generally did not permit

such assets to be removed from a bank's balance sheet. As a result,

assets sold with recourse were included in the asset base used to

calculate a bank's leverage capital ratio.

As a result of the adoption of GAAP as the reporting basis for bank

Call Reports in 1997, banks have now joined savings associations in

being able to remove assets transferred with recourse from their

balance sheets if the transfers qualify for sale treatment under GAAP.

Thus, banks, like savings associations, are not required to hold

leverage capital against assets sold with recourse and this difference

in capital standards was eliminated in 1997.

B.5.b. Senior-Subordinated Structures--Some asset securitization

structures involve the creation of senior and subordinated classes of

securities. When a bank originates such a transaction and retains the

subordinated interest, the banking agencies generally require that the

bank maintain risk-based capital against the entire amount of the asset

pool unless the low-level recourse rule applies.2 However,

when a bank acquires a subordinated interest in a pool of assets that

it did not own, the banking agencies assign the investment in the

subordinated security to the 100 percent risk weight category.

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\2\ When assets are sold with limited recourse, the banking and

thrift agencies' risk-based capital standards limit the amount of

capital that must be maintained against this exposure to the lesser

of the amount of the recourse retained (e.g., through the retention

of a subordinated interest) or the amount of risk-based capital that

would otherwise be required to be held against the assets, i.e., the

full effective risk-based capital charge. This is known as the

``low-level recourse'' rule.

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In general, the OTS requires a thrift that holds the subordinated

interest in a senior-subordinated structure to maintain capital against

the entire amount of the underlying asset pool regardless of whether

the subordinated interest has been retained or has been purchased.

On November 5, 1997, the banking and thrift agencies issued a

proposal that, among other provisions, generally would treat both

retained and purchased subordinated interests similarly for risk-based

capital purposes, i.e., banks and thrifts would be required to hold

capital against the subordinated interest plus all more senior

interests unless the low-level recourse rule applies. The proposal also

includes a multi-level approach to capital requirements for asset

securitizations. The multi-level approach would vary the risk-based

capital requirements for positions in securitizations, including

subordinated interests, according to their relative risk exposure. For

positions that are traded, the risk-based capital treatment would be

based on credit ratings from nationally recognized rating agencies. For

positions that are not traded, the proposal presents three alternative

approaches for determining the risk-based capital requirements. In

general, these alternative approaches would use ratings from two rating

agencies, benchmark guidelines developed by the banking and thrift

agencies, and statistical evaluations of historical loss data. The

comment period for the proposal ended on February 3, 1998.

B.5.c. Recourse Servicing--The right to service loans and other

financial assets may be retained when the assets are sold. This right

also may be acquired from another entity. Regardless of whether

servicing rights are retained or acquired, recourse is present whenever

the servicer must absorb credit losses on the assets being serviced.

The banking agencies and the OTS require risk-based capital to be

maintained against the full amount of assets upon which a selling

institution, as servicer, must absorb credit losses. Additionally, the

OTS applies a capital charge to the full amount of assets being

serviced by a thrift that has purchased the servicing from another

party and is required to absorb credit losses on the assets being

serviced.

The agencies' November 1997 risk-based capital proposal would

require banking organizations that purchase loan servicing rights which

provide loss protection to the owners of the serviced loans to begin to

hold capital against those loans, thereby making the risk-based capital

treatment of these servicing rights uniform for banks and savings

associations.

B.6. Collateralized Transactions

The FRB and the OCC assign a zero percent risk weight to claims

collateralized by cash on deposit in the institution or by securities

issued or guaranteed by the U.S. Government or the central governments

of countries that are members of the Organization of

[[Page 20636]]

Economic Cooperation and Development (OECD), provided a positive margin

of collateral protection is maintained daily.

The FDIC and the OTS assign a 20 percent risk weight to claims

collateralized by cash on deposit in the institution or by securities

issued or guaranteed by the U.S. Government or OECD central

governments.

As part of the Section 303 review of their capital standards, the

banking and thrift agencies issued a joint proposal in August 1996 that

would permit collateralized claims that meet criteria that are uniform

among all four agencies to be eligible for a zero percent risk weight.

In general, this proposal would allow institutions supervised by the

FDIC and the OTS to hold less capital for transactions collateralized

by cash or U.S. or OECD government securities. The proposal would

eliminate the differences among the agencies regarding the capital

treatment of collateralized transactions.

B.7. Presold Residential Construction Loans

The four agencies assign a 50 percent risk weight to loans that a

builder has obtained to finance the construction of one-to-four family

residential properties. These properties must be presold, and the

lending relationship must meet certain other criteria. The OTS and the

OCC rules indicate that the property must be presold before the

construction loan is made in order for the loan to qualify for the 50

percent risk weight. The FDIC and FRB permit loans to builders for

residential construction to qualify for the 50 percent risk weight once

the property is presold, even if that event occurs after the

construction loan has been made.

As a result of their Section 303 review, the agencies' previously

mentioned October 27, 1997, regulatory capital proposal includes a

provision under which the OTS and the OCC would adopt the treatment of

presold residential construction loans followed by the FDIC and the

FRB. This would make the agencies' rules in this area uniform.

B.8. Junior Liens on One-to-Four Family Residential Properties

In some cases, a bank may make two loans on a single residential

property, one secured by a first lien, the other by a second lien. In

this situation, the FRB and the OTS view both loans as a single

extension of credit secured by a first lien and assign the combined

loan amount a 50 percent risk weight if this amount represents a

prudent loan-to-value ratio. If the combined amount exceeds a prudent

loan-to-value ratio, the loans are assigned to the 100 percent risk

weight category. The FDIC also combines the first and second liens to

determine the appropriateness of the loan-to-value ratio, but it

applies the risk weights differently than the FRB and the OTS. If the

combined loan amount represents a prudent loan-to-value ratio, the FDIC

risk weights the first lien at 50 percent and the second lien at 100

percent; otherwise, both liens are risk-weighted at 100 percent. This

combining of first and second liens is intended to avoid possible

circumvention of the capital requirement and to capture the risks

associated with the combined loans.

The OCC treats all first and second liens separately. It assigns

the loan secured by the first lien, if it has been prudently

underwritten, to the 50 percent risk weight category; otherwise, it

assigns the loan to the 100 percent risk weight category. In all cases,

the OCC assigns the loan secured by the second lien to the 100 percent

risk weight category.

As a result of the Section 303 review of their capital standards,

the agencies' October 27, 1997, proposal would extend the OCC's

treatment of junior liens on one-to-four family residential properties

to all four agencies and thereby eliminate this difference among the

agencies.

B.9. Mutual Funds

The banking agencies assign the entire amount of a bank's holdings

in a mutual fund to the risk category appropriate to the highest risk

asset that a particular mutual fund is permitted to hold under its

operating rules. Thus, the banking agencies take into account the

maximum degree of risk to which a bank may be exposed when investing in

a mutual fund because the composition and risk characteristics of the

fund's future holdings cannot be known in advance. In no case, however,

may a risk-weight of less than 20 percent be assigned to an investment

in a mutual fund.

The OTS applies a capital charge appropriate to the riskiest asset

that a mutual fund is actually holding at a particular time, but not

less than 20 percent. In addition, both the OTS and the OCC guidelines

also permit, on a case-by-case basis, investments in mutual funds to be

allocated on a pro rata basis. However, the OTS and the OCC apply the

pro rata allocation differently. While the OTS applies the allocation

based on the actual holdings of the mutual fund, the OCC applies it

based on the highest amount of holdings the fund is permitted to hold

as set forth in its prospectus.

As part of the agencies' Section 303 review of their regulatory

capital standards, one provision of their October 27, 1997, proposal

would apply the banking agencies' treatment of mutual funds to all

institutions. However, the proposal also would permit institutions, at

their option, to adopt the OCC's pro rata allocation alternative for

risk weighting investments in mutual funds. This proposal would make

the agencies' risk-based capital rules in this area uniform, thereby

eliminating this capital difference.

B.10. Noncumulative Perpetual Preferred Stock

Under the banking and thrift agencies' capital standards,

noncumulative perpetual preferred stock is a component of Tier 1

capital. The FDIC's capital standards define noncumulative perpetual

preferred stock as perpetual preferred stock where the issuer has the

option to waive the payment of dividends and where the dividends so

waived do not accumulate to future periods and do not represent a

contingent claim on the issuer. Under the FRB's capital standards,

perpetual preferred stock is noncumulative if the issuer has the

ability and legal right to defer or eliminate preferred dividends. For

these two agencies, for a perpetual preferred stock issue to be

considered noncumulative, the issue may not permit the accruing or

payment of unpaid dividends in any form, including the form of

dividends payable in common stock. Thus, if the issuer of perpetual

preferred stock is required to pay dividends in a form other than cash

when cash dividends are not or cannot be paid, the issuer does not have

the option to waive or eliminate dividends and the stock would not

qualify as noncumulative. The OCC's capital standards do not explicitly

define noncumulative perpetual preferred stock, but the OCC normally

has not considered perpetual preferred stock issues with this type of

dividend requirement to be noncumulative.

The OTS defines as noncumulative those issues of perpetual

preferred stock where the unpaid dividends are not carried over to

subsequent dividend periods. This definition does not address the

issuer's ability to waive dividends. As a result, the OTS has permitted

perpetual preferred stock issues that require the payment of dividends

in the form of stock in the issuer when cash dividends are not paid to

qualify as noncumulative.

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B.11. Limitation on Subordinated Debt and Limited-Life Preferred Stock

Consistent with the Basle Accord, the banking agencies limit the

amount of subordinated debt and intermediate-term preferred stock that

may be treated as part of Tier 2 capital to an amount not to exceed 50

percent of Tier 1 capital. In addition, all maturing capital

instruments must be discounted by 20 percent in each of the last five

years before maturity. The banking agencies adopted this approach in

order to emphasize equity versus debt in the assessment of capital

adequacy.

The OTS has no limitation on the ratio of maturing capital

instruments as part of Tier 2 capital. Also, for all maturing

instruments issued on or after November 7, 1989 (those issued before

are grandfathered with respect to the discounting requirement), thrifts

have the option of using either (a) the discounting approach used by

the banking regulators, or (b) an approach which allows for the full

inclusion of all such instruments provided that the amount maturing in

any one year does not exceed 20 percent of the thrift's total capital.

B.12. Privately-Issued Mortgage-Backed Securities

The banking agencies, in general, place privately-issued mortgage-

backed securities in either the 50 percent or 100 percent risk-weight

category, depending upon the appropriate risk category of the

underlying assets. However, privately-issued mortgage-backed

securities, if collateralized by government agency or government-

sponsored agency securities, are generally assigned to the 20 percent

risk weight category.

The OTS assigns privately-issued high-quality mortgage-related

securities to the 20 percent risk weight category. These are,

generally, privately-issued mortgage-backed securities with AA or

better investment ratings.

B.13. Other Mortgage-Backed Securities

The banking agencies and the OTS automatically assign to the 100

percent risk weight category certain mortgage-backed securities,

including interest-only strips, principal-only strips, and residuals.

However, once the OTS' interest rate risk amendments to its risk-based

capital standards take effect, stripped mortgage-backed securities will

be reassigned to the 20 percent or 50 percent risk weight category,

depending upon these securities' characteristics. Residuals will remain

in the 100 percent risk weight category.

B.14. Nonresidential Construction and Land Loans

The banking agencies assign loans for nonresidential real estate

development and construction purposes to the 100 percent risk weight

category. The OTS generally assigns these loans to the same 100 percent

risk category. However, if the amount of the loan exceeds 80 percent of

the fair value of the property, the excess portion is deducted from

capital.

B.15. ``Covered Assets''

The banking agencies generally place assets subject to guarantee

arrangements by the FDIC or the former Federal Savings and Loan

Insurance Corporation in the 20 percent risk weight category. The OTS

places these ``covered assets'' in the zero percent risk-weight

category.

B.16. Pledged Deposits and Nonwithdrawable Accounts

Instruments such as pledged deposits, nonwithdrawable accounts,

Income Capital Certificates, and Mutual Capital Certificates do not

exist in the banking industry and are not addressed in the banking

agencies' capital standards.

The OTS' capital standards permit savings associations to include

pledged deposits and nonwithdrawable accounts that meet OTS criteria,

Income Capital Certificates, and Mutual Capital Certificates in

regulatory capital.

B.17. Agricultural Loan Loss Amortization

In the computation of regulatory capital, those banks accepted into

the agricultural loan loss amortization program pursuant to Title VIII

of the Competitive Equality Banking Act of 1987 may defer and amortize

certain losses related to agricultural lending that were incurred on or

before December 31, 1991. These losses must be amortized over seven

years. The unamortized portion of these losses is included as an

element of Tier 2 capital under the banking agencies' risk-based

capital standards.

Thrifts were not eligible to participate in the agricultural loan

loss amortization program established by this statute.

Because the banking agencies' agricultural loan loss amortization

program ends on December 31, 1998, this difference will disappear on

that date.

C. Differences in Accounting Standards Among the Federal Banking and

Thrift Agencies

C.1. Push Down Accounting

Push down accounting is the establishment of a new accounting basis

for a depository institution in its separate financial statements as a

result of a substantive change in control. Under push down accounting,

when a depository institution is acquired in a purchase (but not in a

pooling of interests), yet retains its separate corporate existence,

the assets and liabilities of the acquired institution are restated to

their fair values as of the acquisition date. These values, including

any goodwill, are reflected in the separate financial statements of the

acquired institution as well as in any consolidated financial

statements of the institution's parent.

The banking agencies require push down accounting when there is at

least a 95 percent change in ownership. This approach is generally

consistent with accounting interpretations issued by the staff of the

Securities and Exchange Commission.

The OTS requires push down accounting when there is at least a 90

percent change in ownership.

C.2. Negative Goodwill

Under Accounting Principles Board Opinion No. 16, ``Business

Combinations,'' negative goodwill arises when the fair value of the net

assets acquired in a purchase business combination exceeds the cost of

the acquisition and a portion of this excess remains after the values

otherwise assignable to the acquired noncurrent assets have been

reduced to zero.

The banking agencies require negative goodwill to be reported as a

liability on the balance sheet and do not permit it to be netted

against goodwill that is included as an asset. This ensures that all

goodwill assets are deducted in regulatory capital calculations

consistent with the internationally agreed-upon Basle Accord.

The OTS permits negative goodwill to offset goodwill assets on the

balance sheet.

Dated at Washington, D.C., this 21th day of April, 1998.

Federal Deposit Insurance Corporation.

Robert E. Feldman,

Executive Secretary.

[FR Doc. 98-11028 Filed 4-24-98; 8:45 am]

BILLING CODE 6714-01-P