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B-332079 1 (2020-04-17)

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cAO U.S. GOVERNMENT ACCOUNTABILITY OFFICE
441 G St. N.W.
Washington, DC 20548


B-332079


April 17, 2020

The Honorable Mike Crapo
Chairman
The Honorable Sherrod Brown
Ranking Member
Committee on Banking, Housing, and Urban Affairs
United States Senate

The Honorable Maxine Waters
Chairwoman
The Honorable Patrick McHenry
Ranking Member
Committee on Financial Services
House of Representatives

Subject: Department of the Treasury, Office of the Comptroller of the Currency; Federal
        Reserve System; Federal Deposit Insurance Corporation: Regulatory Capital Rule:
        Revised Transition of the Current Expected Credit Losses Methodology for Allowances

Pursuant to section 801 (a)(2)(A) of title 5, United States Code, this is our report on a major rule
promulgated by the Department of the Treasury, Office of the Comptroller of the Currency;
Federal Reserve System; Federal Deposit Insurance Corporation (the agencies) entitled
Regulatory Capital Rule: Revised Transition of the Current Expected Credit Losses
Methodology for Allowances (RI Ns: 1557-AE82, 71 00-AF82, 3064-AF42). We received the
rule on April 6, 2020. It was published in the Federal Register as an interim final rule, request
for comment on March 31, 2020. 85 Fed. Reg. 17723. The effective date of the rule is
March 31, 2020.

The interim final rule delays the estimated impact on regulatory capital stemming from the
implementation of Accounting Standards Update No. 2016-13, Financial Instruments-Credit
Losses, Topic 326, Measurement of Credit Losses on Financial Instruments (CECL), according
to the agencies. The agencies state that the interim final rule provides banking organizations
that implement CECL before the end of 2020 the option to delay for 2 years an estimate of
CECL's effect on regulatory capital, relative to the incurred loss methodology's effect on
regulatory capital, followed by a 3-year transition period. The agencies state they are providing
this relief to allow such banking organizations to better focus on supporting lending to
creditworthy households and businesses in light of recent strains on the U.S. economy as a
result of the coronavirus disease 2019 (COVID-19), while also maintaining the quality of
regulatory capital.

The Congressional Review Act (CRA) requires a 60-day delay in the effective date of a major
rule from the date of publication in the Federal Register or receipt of the rule by Congress,
whichever is later. 5 U.S.C. § 801(a)(3)(A). The 60-day delay in effective date can be waived,

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