ARTICLE
10 January 2022

Federal Banking Agencies Provide Guidance On CBLR Framework

CW
Cadwalader, Wickersham & Taft LLP

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After the grace period, the banking organization must meet all qualifying requirements in order to remain in the framework.
United States Finance and Banking
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In an interagency statement, Federal banking agencies provided information and guidance on the use of the two-quarter grace period under the optional community bank leverage ratio ("CBLR") framework once temporary relief measures expire on December 31, 2021.

The agencies specified that a banking organization electing the optional CBLR framework will be subject to the 9 percent CBLR requirement and must use total consolidated assets as of the report date to determine eligibility. The CBLR framework includes a two-quarter grace period allowing banking organizations extra time to build capital and manage their balance sheets to either remain in the framework or comply with the generally applicable risk-based and leverage capital requirements.

According to the statement, a banking organization may not be required to report a greater than 9 percent CBLR until the June 30, 2022, or September 30, 2022, regulatory filings, depending on whether a banking organization is currently in its grace period and when that grace period began. A banking organization in the CBLR framework must report a greater than 8 percent leverage ratio to use the two-quarter grace period starting on January 1, 2022. After the grace period, the banking organization must meet all qualifying requirements in order to remain in the framework.

Primary Sources

  1. Interagency Statement on the Community Bank Leverage Ratio Framework
  2. Interagency Statement on the Community Bank Leverage Ratio Framework
  3. Community Bank Compliance Guide

The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.

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