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B-332638 1 (2020-11-02)

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c)AO U.S. GOVERNMENT ACCOUNTABILITY OFFICE
441 G St. N.W.
Washington, DC  20548


B-332638


November  2, 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
(OCC); Federal Reserve System (Board); Federal Deposit Insurance Corporation (FDIC)
(collectively, the agencies) entitled Regulatory Capital Rule: Revised Transition of the Current
Expected Credit Losses Methodology for Allowances (RINs: 1557-AE82, 7100-AF82; 3064-
AF42). We  received the rule on October 19, 2020. It was published in the Federal Register as
a final rule on September 30, 2020. 85 Fed. Reg. 61577. The effective date of the rule is
September  30, 2020.

According to the agencies, the 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). The agencies state the final rule provides banking organizations that
implement CECL  during the 2020 calendar year 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 these 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, 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,
however, if the agency finds for good cause that delay is impracticable, unnecessary, or

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