We believe that the agencies should tailor applicable rules to the characteristics, activities, and risks of the diverse range of savings and loan holding companies.Based on those concerns, they recommended, among other things, that the agencies modify the Basel III proposals so they would:
We also believe that the [Basel III proposals] do not give full effect to the terms of [the Dodd-Frank Act’s Section 171]—including the delayed effective date for the application of capital standards for savings and loan holding companies—and this creates additional compliance burdens for [for such] companies.
- Provide for the application of capital standards to S&L holding companies as of July 21, 2015, not 2013.
- Grant small S&L holding companies the same general exemption proposed for small bank holding companies.
- Grandfather trust preferred securities issued before May 19, 2010, by S&L holding companies with less than $15 billion in assets.
- Maintain the accumulated other comprehensive income filter.
- Avoid overly conservative capital standards for residential mortgages, which constitute a significant portion of savings and loan assets.
- Conduct a study on the proposed capital standards’ impact on residential mortgages to develop standards that don’t overly restrict mortgage lending and needlessly impair economic growth.