1 USAA 9800 Fredericksburg Road San Antonio, Texas October 22, 2012 Office of the Comptroller of the Currency 250 E Street, SW Mail Stop 2-3 Washington, DC Ms. Jennifer J. Johnson, Secretary Board of Governors of the Federal Reserve System 20th Street and Constitution Avenue, NW Washington, DC Mr. Robert E. Feldman, Executive Secretary Attention: Comments Federal Deposit Insurance Corporation th Street, NW Washington, DC Re: Regulatory Capital Rules: Regulatory Capital, Implementation of Basel III, Minimum Regulatory Capital Ratios, Capital Adequacy, Transition Provisions, and Prompt Corrective Action (OCC: Docket No. OCC and RIN 1557-AD46: FRB: Docket No. R-1442 and RIN 7100-AD-87: FDIC: RIN 3064-AD95) (NPR 1) Regulatory Capital Rules: Standardized Approach for Risk-Weighted Assets: Market Discipline and Disclosure Requirements (OCC: Docket No. QCC and RIN 1557-AD46: FRB: Docket No. R-l442 and RIN 7100-AD-87: FDIC: RIN AD96) (NPR 2) Ladies and Gentlemen: United Services Automobile Association (USAA) is pleased to provide our comments with respect to the two above-described proposed rules regarding regulatory capital (the Proposed Rules) that the Office of the Comptroller of the Currency, the Board of Governors of the Federal Reserve System (the Board) and the Federal Deposit Insurance Corporation (collectively, the Agencies) jointly proposed under the Dodd-Frank Wall Street Reform and Consumer Protection Act (Dodd-Frank).Footnote1. Regulatory Capital Rules, 77 Fed. Reg (proposed August 30, 2012); Regulatory Capital Rules, 77 Fed. Reg (proposed August 30, 2012).Endoffootnote.
2 USAA is a membership-based association, which together with its family of companies, serves present and former commissioned and noncommissioned U.S. military officers, enlisted and retired military personnel, and their families.page2. Since USAA's inception in 1922 by a group of U.S. Army officers, we have pursued a mission of facilitating the financial security of our members and their families by providing a full range of highly competitive financial products and services, including personal lines of insurance, retail banking and investment products. Our core values of service, honesty, loyalty and integrity have enabled us to perform consistently and be a source of stability for our members, even in the midst of the unprecedented financial crisis of recent years. USAA is a holding company for a diversified financial services group of companies and is itself a personal lines property and casualty insurance carrier. USAA's affiliated companies enhance our product and geographic diversification, and our overall financial strength benefits from our diversification into life insurance, banking, investments and other products and services. USAA Life Insurance Company (USAA Life), a subsidiary of USAA, offers life insurance, annuities and health insurance products and services to our members. USAA Federal Savings Bank (USAA Bank), an indirect wholly owned subsidiary of USAA, is a federally chartered savings association organized to offer personal retail banking services, including home mortgages and automobile loans to our members. Because USAA Bank was chartered in 1983, and is USAA's only savings association, USAA is a grandfathered unitary savings and loan holding company (SLHC) that was previously regulated by the Office of Thrift Supervision. As such, USAA has not previously been subject to the Bank Holding Company (BHC) risk-based capital adequacy guidelines found in Appendix A of Regulation Y. A. Summary The Proposed Rules largely ignore the insurance-specific risk-based capital regime and related accounting and reserving requirements developed to address the risks inherent in the insurance industry. Imposing a one-size-fits-all framework on insurers will have negative consequences for insurers and for the overall economy, and will not achieve the objectives the Agencies seek to attain by proposing these rules. Our letter urges the Agencies to avoid the so-called "double-counting" of insurance assets by adopting the "deduction and deconsolidation" approach as proposed by the Basel Committee on Banking Supervision but rejected by the Board's final rule entitled "Risk-Based Capital Standards: Advanced Capital Adequacy Framework - Basel II" published on December 7, 2007Footnote2. (hereinafter "2007 Advanced Framework" or the Framework ). Alternatively, the Agencies could provide SLHCs that have insurance underwriting subsidiaries and SLHCs that are themselves operating insurance underwriters (collectively referred to in this letter as "Insurance SLHCs"), the option to deduct an amount of capital related to insurance underwriting activities that is higher than the Risk-Based Capital Standards, 72 Fed. Reg , (December 7, 2007).Endoffootnote.
3 minimum regulatory capital requirement of the insurance underwriting entities within the holding company, and to deconsolidate the assets of those insurance underwriting entities when determining the consolidated regulatory capital of the company pursuant to the Proposed Rules.Page3. The Agencies should postpone until at least January 1, 2015, the Basel III implementation deadline for SLHCs which do not currently use Basel 1 risk-based capital rules or BHC capital adequacy guidelines. Finally, we request the Agencies make certain changes relating to the risk-weighting for certain asset classes (e.g., asset backed securities and equities). B. Adopt the "deduction and deconsolidation approach" for SLHCs that have insurance underwriting subsidiaries or are themselves insurance underwriters. The Proposed Rules require deduction of an amount of capital equal to 200% of the Authorized Control Level (ACL) of any insurance underwriting subsidiary of an SLHC from the numerator of its consolidated risk-based capital ratio without a corresponding deduction of the assets of those insurance subsidiaries from the denominator of the ratio. This approach places an unfair and inappropriate burden on Insurance SLHCs by effectively "double-counting" in the consolidated assets of the SLHC those assets relating to insurance underwriting used to calculate the minimum capital requirement of the insurance underwriting entities within the SLHC. Instead, the deduction and deconsolidation approach endorsed by the Basel Committee should be adopted by the Agencies in order to appropriately recognize insurance underwriting risks. We propose that the Agencies require an Insurance SLHC to deduct 200% of the ACL of its insurance underwriting entities and deconsolidate the assets of those insurance underwriting entities subject to state insurance regulatory requirements.footnote3. The Agencies state that the rejection of the deduction and deconsolidation approach in the Proposed Rules is consistent with the 2007 Advanced Framework. It is important to note, however, that the Framework applied only to "core banks," which are essentially very large, internationally active banking organizations.footnote4. In determining whether a banking organization meets the required thresholds to be defined as a core bank, the 2007 Advanced Framework allows an organization to exclude from its total consolidated assets the assets held by any insurance underwriting subsidiary. Therefore, it is unlikely that any Insurance SLHC was then, or is now, a core bank as defined by the 2007 Advanced Framework. For this reason, we do not believe the Agencies fully considered the impact that rejecting the deduction and deconsolidation approach would have on Insurance SLHCs. We urge the Agencies to reconsider the merits of that approach at least with respect to SLHCs. Explaining its rejection of the full deduction and deconsolidation approach in the 2007 Advanced Framework, the Board stated that a consolidated BHC risk-based capital measure should (1) If this proposal is accepted, the deduction could be applied to the parent insurance underwriter as well.endoffootnote. A core bank is defined as a banking organization that holds either: (i) consolidated total assets of $250 billion or more, or (ii) consolidated total on-balance sheet foreign exposures of $10 billion or more.endoffootnote.
4 incorporate all credit, market, and operational risks to which the depository institution holding company is exposed, (2) minimize the potential for regulatory capital arbitrage, and (3) reflect the consolidated organization.page4. The Board opposed the deduction and deconsolidation approach because, in the Board's view, the state insurance risk-based capital requirements do not consider credit risk and the deconsolidation approach creates opportunities for regulatory arbitrage with respect to insurance underwriter versus depository institution holding company regulatory capital requirements. We address each concern in turn below: 1. Insurance risk-based capital calculations do incorporate credit, market and operational risk State regulators impose upon Insurance SLHCs strict, comprehensive risk-based capital standards. These standards do, in fact, take into account credit, as well as market and operational risks to which Insurance SLHCs are exposed, including risks posed by insurance underwriting subsidiaries. USAA's state regulator indentifies various risk categories in its risk-based capital model: asset risk of affiliates; other asset risk, including credit risk, interest rate risk and market risk; underwriting risk or insurance risk; and business risk.footnote5. Credit risk under the insurance risk-based capital model represents the potential for default of principal and interest or fluctuation in fair value of assets, including fixed income and equity. Fixed income assets include bonds, collateral loans and mortgage loans, short-term investments, cash, and other long-term investment assets. Equity assets include unaffiliated common and preferred stock, real estate, and long-term assets. Additionally, all insurance companies are subject to an asset concentration factor that reflects the additional risk of high concentrations in a single issuer.footnote6. Fixed income and equity investments constitute a significant and essential part of any insurer's portfolio, and insurance regulations appropriately and effectively address the credit risk these assets present. 2. The deconsolidation approach does not result in regulatory arbitrage. The Board previously stated that a fully consolidated approach minimizes the potential for regulatory capital arbitrage, because it avoids creating an incentive to book individual asset exposures at a subsidiary to obtain potentially more favorable capital treatment. With respect to Insurance SLHCs, the deconsolidation approach does not incent regulatory arbitrage but, instead, is an effective means of balancing the interests of the Agencies and insurance regulators. Deconsolidation allows an Insurance SLHC to manage, on a consolidated basis, the required amounts of capital to appropriately address risks presented by banking and insurance underwriting activities. It permits the Insurance SLHC to maintain sufficient capital to protect consumers, who in USAA's case are its members, through strong insurance claims payment Risk categories are based on the National Association of Insurance Commissioners (NAIC) Risk-Based Capital for Insurers Model Act (Volume ). Most U.S. insurance jurisdictions have adopted statutes, regulations or bulletins that are substantially similar to the NAIC Model Act 312. See also the excellent discussion of how the state insurance regulatory risk-based capital framework specifically accounts for the same asset-specific risks identified in NPR 1 and NPR 2 in the comment letter submitted by the American Council of Life Insurers.Endoffootnote. NAIC Risk-Based Capital General Overview, July 15, 2009, at e_capad_rbcoverview.pdf.endoffootnote.
5 capability and by serving as a significant source of strength to its insured depository institution subsidiaries.page5. Subjecting insurance-related assets to an insurance-centric capital rule and subjecting all other assets of the SLHC to a bank-centric capital rule is a simple and prudent approach to management and control of all risks inherent in an Insurance SLHC. Insurance underwriting necessitates significant investments in debt and equity securities and other assets that generally have longer average maturities or durations than investments in a depository institution liquidity portfolio. Using the deconsolidation approach, investments in these assets classes for insurance underwriting purposes would be subject to appropriate insurance capital standards and be excluded from the capital standards in the Proposed Rule that are not designed to measure or address insurance underwriting risks. We believe Congress's adoption of the insurance company exception to the Volcker Rule's prohibition on proprietary trading effectively required separation of insurance and banking investments for purposes of applying the Volcker Rule and supports the argument that deconsolidation of insurance assets is appropriate. The exception recognizes that the ability to make certain investments (that are generally prohibited for banks) must be preserved for insurers because those investments are essential to the safe and effective operation of an insurance business.footnote7. In the Volcker Rule context, we are not aware of concerns indicating that regulatory arbitrage may result from the insurance company exception. We submit that the same reasoning applies to the deconsolidation of insurance assets, and it will not result in regulatory arbitrage. 3. The insurance-based capital requirements reflect the consolidated enterprise. The Board has stated that the capital requirements imposed by a functional regulator at the subsidiary level reflect the capital needs at the particular subsidiary and that the consolidated measure of minimum capital requirements should reflect the consolidated organization. This is not the case for a reciprocal (like USAA) or mutual insurance company that is an Insurance SLHC. In USAA's structure, the ultimate parent company within the Insurance SLHC is an insurance underwriter, and the capital requirements imposed by the functional regulator reflect the consolidated organization. Thus, at a minimum, the Board's rationale for rejecting deconsolidation does not apply when the Insurance SLHC is itself an operating insurance underwriter. Moreover, deduction and deconsolidation is the right approach because it allows the Agencies to appropriately coordinate with state functional regulators.footnote8. Acknowledging the nature of insurance underwriting, Congress excluded from the Volcker Rule's prohibition those investments that are "for the general account" of an insurer, provided those investments are permitted by applicable state insurance law.endoffootnote. See Section 604(g) of Dodd-Frank stating that the Agencies must use: "(i) reports and other supervisory information that the savings and loan holding company or any subsidiary thereof has been required to provide to other Federal or State regulatory agencies; "(ii) externally audited financial statements of the savings and loan holding company or subsidiary; "(iii) information that is otherwise available from Federal or State regulatory agencies; and "(iv) information that is otherwise required to be reported publicly.
6 supervisory information and coordination with state regulators, thereby recognizing and supporting state authority and rulemaking when applying consolidated capital requirements to an Insurance SLHC.Page6. The Agencies should deconsolidate insurance underwriting assets in an Insurance SLHC when determining consolidated banking capital requirements in recognition of the responsibility of state insurance regulators to impose meaningful capital requirements on the consolidated Insurance SLHC. With respect to an Insurance SLHC, deduction of the minimum regulatory capital requirement of insurance underwriting entities ("200 percent of the subsidiary's Authorized Control Level as established by the appropriate state regulator of the insurance company") must be accompanied by a corresponding deduction of the assets of the insurance underwriting entities that are used to establish that minimum insurance regulatory capital requirement. C. If the full deduction and deconsolidation approach is not adopted, give an Insurance SLHC the option to deconsolidate insurance underwriting assets provided it deducts an amount of capital equal to a greater percentage of Authorized Control Level. If the full deduction and deconsolidation approach is not adopted, the Agencies should give an Insurance SLHC the option to deconsolidate its consolidated insurance assets when determining consolidated regulatory capital requirements under the Proposed Rules provided it deducts a greater amount of insurance underwriting subsidiary capital than is stated in the Proposed Rules (e.g., 300% of ACL). D. Avoid Double Implementation of Basel I and Basel III for SLHCs. The Proposed Rules provide for a phase-in of Basel III for BHCs by allowing BHCs to calculate risk-weighted assets using methodologies in Basel I. However, USAA, as an insurer and SLHC, has never been required to comply with Basel I risk-based capital rules. As a result, application on January 1, 2013 of the new Basel III capital standards outlined in NPR 1 results in a costly, complex two-step implementation process that unfairly burdens SLHCs like USAA. These requirements would force USAA to implement current Basel I capital rules, which will require USAA to design systems to accurately risk-weight total consolidated assets according to the "current" rules, and to simultaneously develop new technologies and new monitoring and reporting systems, processes, and strategies in order to be prepared to implement the new riskweighting rules under NPR 2 by This implementation schedule imposes unnecessary and burdensome costs on Insurance SLHCs. Moreover, these standards are not necessary since these companies already meet rigorous, riskbased capital requirements imposed by state insurance regulators. See also Dodd-Frank Section 604(h)(2) (stating that the Board should coordinate with other regulators); and see Board of Governors of the Federal Reserve System, Division of Banking Supervision and regulation, Division of Consumer and Community Affairs, SR 08-9 / CA 08-12, dated October 16, 2008 (SR 08-9 "reiterates the importance of coordination with, and reliance on, the work of other relevant primary supervisors and functional regulators").endoffootnote.dodd-frankrequirestheuseof.
7 By, in effect, requiring SLHCs like USAA to manage to two sets of new rules by 2015, the Agencies are imposing unfair burden on those SLHCs and providing an advantage to BHCs that are already managing capital and risk in accordance with Basel I.Page7. Moreover, USAA and other Insurance SLHCs are currently burdened with a variety of other new regulatory requirements associated with Dodd-Frank, such as regulatory reporting to the Board, stress testing and capital plans, none of which are new for BHCs. This double implementation process is an additional, unnecessary burden to place on SLHCs. We respectfully request that the Agencies clarify that if an SLHC is not currently using Basel I, it does not need to implement the risk-based capital requirements using Basel I by January 1, Instead, these SLHCs should comply with Basel III by the 2015 deadline only. This timeline is supported by Congress in the Collins Amendment, Section 171(b)(4)(D) of Dodd-Frank, which provides that SLHCs have until 2015 to implement Basel III. E. Provide Risk-Weighting Relief for Asset-Backed Securities and Equities. As discussed above, USAA is a diversified financial services institution. It is our mission to provide a full range of highly competitive financial products and services to members of the U.S. military community. Military families have unique financial services needs because they face deployment, overseas assignments and frequent duty station changes. As a result, servicemembers often use overseas banking, remote (online or mobile) banking, wire transfers and foreign automobile and renters insurance. Families frequently moving across state lines need auto title changes, new insurance policies, and easy access to banking services. Active duty servicemembers in combat situations or with war-related disabilities have specialized life insurance needs. USAA is one of the few providers of these specialized services. USAA strives to provide insurance, banking and other financial services in a seamless and dependable manner during all the events in our members' lives. USAA has grown deliberately by developing products based on the needs of our members. Our diversification across banking, personal lines insurance, life insurance, brokerage, mutual funds and retirement services has allowed USAA to flourish throughout numerous financial and nonfinancial crises and to meet or exceed applicable regulatory requirements. Our experience is that strong insurance operations positively impact the financial strength of the SLHC and the depository institution it supports. The Proposed Rules, however, could hinder USAA's efforts and ability to competitively provide a full range of products - to maintain this diversification and fulfill these unique needs of the military community. This is particularly true of USAA Life Company. As a result, and in addition to the changes to the Proposed Rule discussed previously in this letter, we urge the Agencies to make certain changes to specific asset risk-weightings in the Proposed Rules. We believe the following three adjustments to the risk-weightings of assets will help account for the investment needs of insurers and thereby better serve our military constituents: 1. The Supervisory Simplified Formula Approach (SSFA) and gross up risk-weight method (Gross Up Method) are overly complex and unnecessarily difficult to implement.
8 The processes supporting the SSFA and Gross-Up Method are complicated, time-intensive and overly dependent upon vital information from third parties to determine accurate risk-weightings for securitization exposures.page8. In order to make correct calculations under these approaches, banking organizations will need very specific and detailed information from issuers, servicer/trustee reports or other third party providers (e.g., Intex, Bloomberg), who generally do not provide the necessary information. This reliance is problematic in that collateral performance may not be available for all securitization exposures (e.g., foreign securitizations), and there are inconsistencies across the industry with respect to the standards and definitions used to make those calculations (e.g, there is no industry standard for reporting CUSIP level information and the term "default" is not clearly defined). These complicated approaches will place SLHCs and other banking organizations at risk for inaccuracies or inconsistencies, and will require additional, comprehensive steps to audit data providers to ensure that reporting is verified and reliable. Other requirements under the SSFA and Gross-Up Method are also extremely onerous for Insurance SLHCs. For example, the requirement to model CUSIP level investments as well as mutual fund look-through risk weights adds a substantial burden to insurance companies that hold these investments and does not add value in quantifying risk exposure. Moreover, the Proposed Rules make forecasting future risk-weighting of assets very difficult, if not impossible, because such forecasting requires: (i) anticipating the composition of forecasted portfolios at the CUSIP level and (ii) predicting deal and collateral specific performance. The dependability of underlying forecasting assumptions can be suspect. For example, in 2006 it is improbable that any banking organization would have forecasted declining residential mortgage backed securities performance using the SSFA approach. Therefore, this particular risk-weighted asset approach would not have indicated a need to increase capital levels to address a looming credit crisis. The capital conservation buffer included in NPR 1 is a more appropriate and effective way to address the need to hold more capital to prepare for times of financial stress. 2. Risk-weights and risk exposure are inconsistent across asset classes. Under the Proposed Rules, the risk-weightings for corporate bonds and equity exposure are 100% and 300%, respectively. For certain securitization exposures, depending on the methodology, the risk-weighting could exceed 1250%. These weightings are unrealistic and onerous, especially to insurance companies that invest heavily in these long-term assets. Moreover, this risk-weighting does not correspond to the actual risk the product presents to an investor (as opposed to an issuer). Asset-backed securities are collateralized, contain diverse and numerous underlying assets, and are structured to expose the investor to less risk. Additionally, insurers often invest in student-loan backed ABS where up to 98% of collateral performance is guaranteed by the U.S. government. The SSFA and the Gross-Up Method do not give credit to this guarantee. The ABS is modeled through traditional risk weightings, which may result in a risk weight of 1250%) under SSFA and over 1250%) risk weight under the Gross- Up method. We suggest the Agencies forego the SSFA or Gross-Up Method when there is underlying collateral or a government guarantee and instead rely on the standard risk-weight for agency or GSE securitization exposures.
9 3. Risk weightings for certain asset classes increase insurance risk..page9. ABS and equities are important investments for insurance companies. ABS investments match appropriately with long-term insurance risks by providing long-term, stable income. Equities provide diversity and growth opportunities. The higher risk weighting of these certain long-term investment assets (up to 1250% for ABS and 600% for equities) will make them less attractive for insurers to hold. In other words, subjecting insurers to bank-centric capital standards, which generally encourage relatively shortterm investments for bank liquidity purposes, could prompt insurers to decrease their investments in longer term assets. Decreasing longer term investments will negatively impact users of insurance and retirement products. The Agencies should ensure that the Proposed Rules do not inadvertently encourage investment behaviors that may increase insurance product risks. An insurer must have the ability to manage an investment portfolio composed of short and longterm investments designed to provide resources for the payment of all types of claims (e.g., property damage resulting from a minor automobile accident; complete and catastrophic loss of a home and other property in a major weather event; a death that triggers payout on a life insurance policy). Placing massive risk weights on long-term investments would seriously hinder the management of insurance portfolios. F. Conclusion The Proposed Rules are overly burdensome because the Agencies appear to have taken a onesize-fits-all approach to measuring risk exposure and the correlating risk-based capital requirements. In their present form, the Proposed Rules are likely to incent investment management practices that would hinder the management of risk in insurance underwriting. USAA is concerned that the proposed capital rules are not fully aligned with each other, and will create an inefficient capital burden on the banking and insurance industries. For example, the purpose of conservation capital in the Proposed Rules is to ensure that banking organizations build up capital buffers that can be drawn down as losses are incurred. Meanwhile, SSFA will result in higher risk-weightings of assets in times of stress, exacerbating banking organizations' capital Sustainability and adequacy. Insurance companies provide a significant source of long-term stable funding for the corporate, real estate, and governmental sectors. The overall impact of the potential capital inefficiencies created by the Proposed Rules will, inevitably, be passed through to various stakeholders including but not limited to, employees, the debt and equity markets, consumers, policyholders, depositors and ultimately the U.S. economy. We appreciate the important role the Agencies play in providing for the safe and sound operation of the banking system in the U.S. We are confident that this objective can be met by allowing historically safe and sound institutions like USAA to continue providing a diversified, full range of financial services and products to customers at competitive prices. We also appreciate the
10 Agencies' consideration of our comments.page10. Should you have any questions or wish further clarification or discussion of our points, please contact Kristine Thomas, Vice President, Corporate Regulatory Counsel, at Sincerely. signed. Steven Alan Bennett Executive Vice President General Counsel & Corporate Secretary
USAA 9800 Fredericksburg Road San Antonio, Texas 78288 April 30, 2012 Ms. Jennifer J. Johnson, Secretary Board of Governors of the Federal Reserve System 20th Street and Constitution Avenue, NW Washington,
SÇ ^ USAA @ 9800 Fredericksburg Road ^nt0n ' 0, Texas 7^288 February 13, 2012 Office of the Comptroller of the Currency 250 E Street, SW Mail Stop 2-3 Washington, DC 20219 regs. comment s@occ. trecis.gov
Nationwide. Mark R. Thresher. Executive Vice President. Chief Financial Officer. Nationwide Insurance. VIA ELECTRONIC TRANSMISSION. www.regulations.gov June 12, 2013. Robert dev. Frierson, Secretary. Board
OFFICE OF G» S E THE AUTO CLUB GROUP 1 AUTO CLUB DRIVE, DEARBORN, MICHIGAN 4 S 126 JOHN BRUNO, VICE PRESIDENT ESQUIRE DEPUTY GENERAL COUNSEL OFFICE OF GENERAL COUNSEL TELEPHONE: (313) 336-1795 FACSIMILE:
NATIONAL ASSOCIATION OF MUTUAL INSURANCE COMPANIES October 24, 2011 Ms. Jennifer Johnson Secretary Board of Governors of the Federal Reserve System 20th Street and Constitution Avenue, N.W. Washington,
March 26, 2007 Office of the Comptroller of the Currency 250 E Street, S.W. Mail Stop 1-5 Washington, DC 20219 Jennifer J. Johnson Secretary Board of Governors of the Federal Reserve System 20th Street
March 26, 2007 Office of the Comptroller of the Currency 250 E Street, S.W. Mail Stop 1-5 Washington, DC 20219 Jennifer J. Johnson Secretary Board of Governors of the Federal Reserve System 20 th Street
ni LPL Financial 97S5 Towne Centre Drive San Diego, CA 92121-196S S5S 450 9606 office January 31, 2014 Office of the Comptroller of the Currency 400 7 th Street, S.W., Suite 3E-218 Mail Stop 9W-11 Washington,
SHELTER INSURANCE COMPANIES CHRISTINA M. WORKMAN VICE PRESIDENT OF ACCOUNTING (5 7 3) 2 1 4-4 5 7 4 www.shelterinsurance.com April 11, 2011 Jennifer J. Johnson Secretary Board of Governors of the Federal
Introduction Basis of the Financial Stability Oversight Council s Final Determination Regarding General Electric Capital Corporation, Inc. Pursuant to section 113 of the Dodd-Frank Wall Street Reform and
Regulation Comments Chief Counsel's Office Office of Thrift Supervision 1700 G Street, N.W. Washington, DC 20552 Re: No. 2006-33 Ms. Jennifer J. Johnson Secretary Board of Governors of the Federal Reserve
American Insurance Association April 30, 2013 2101 L Street.NW Suite 400 Washington,DC 20037 202-828-7100 Fax 202-293-1219 www.aiadc.org BY ELECTRONIC MAIL Board of Governors of the Federal Reserve System
AUBURN BANK October 22, 2012 Jennifer J. Johnson, Secretary Board of Governors of the Federal Reserve System 20 111 Street and Constitution A venue, NW Washington, DC 20551 Office of the Comptroller of
BOARD OF GOVERNORS OF THE FEDERAL RESERVE SYSTEM Date: To: From: Subject: June 3, 2016 Board of Governors / Governor Tarullo'J)l-! Advance notice of proposed rulemaking regarding capital requirements for
VIA ELECTRONIC TRANSMISSION www.regulations.gov October 17, 2012 The Honorable Ben S. Bernanke Chairman Board of Governors of the Federal Reserve System 20th Street & Constitution Ave., NW. Washington,
Hugh Carney Senior Counsel P 202-663-5324 firstname.lastname@example.org By Email: email@example.com; firstname.lastname@example.org; email@example.com May 14, 2013 Robert dev. Frierson Secretary Board of
441 G St. N.W. Washington, DC 20548 B-325793 May 7, 2014 The Honorable Tim Johnson Chairman The Honorable Mike Crapo Ranking Member Committee on Banking, Housing, and Urban Affairs United States Senate
Supporting Statement for the Reporting, Recordkeeping, and Disclosure Requirements Associated with Regulation VV (Proprietary Trading and Certain Interests in and Relationships with Covered Funds) (Reg
COUNTRY FINANCIAL 1701 N Towanda Avenue PO Box 2020 Bloomington, I L 6 1 702-20 20 309-821-3000 www.country financial.com BY EMAIL Jennifer J. Johnson Secretary Board of Governors of the Federal Reserve
May 16, 2011 Communications Division Mr. Gary A. Kuiper Office of the Comptroller Counsel of the Currency Room F 1086 Mailstop 2 3 Washington, D.C. 20219 550 17 th Street, N.W. Attention: 1557 0081 Washington,
Federal Agricultural Mortgage Corporation 1133 Twenty-First Street, N.W. Washington, D.C. 20036 202-872-7700 FAX 202-872-7713 800-879-FARM www.farmermac.com Via Electronic Mail To: Mr. Gary K. Van Meter
James Chessen, Ph.D. Chief Economist (202) 663-5130 firstname.lastname@example.org May 16, 2011 Communications Division Ms. Jennifer J. Johnson Office of the Comptroller of the Currency Secretary Mail Stop 2-3 Board
May 20,2008 VIA EMAIL Office of the Comptroller of the Currency 250 E Street, SW., Mail Stop 1-5 Washington, DC 2021 9 Reqs.email@example.com Docket ID OCC-2008-0002 Mr. Robert E. Feldman, Executive
1 Client Update Federal Reserve Publishes Advance Notice of Proposed Rulemaking on Capital Requirements for Insurers NEW YORK Alexander R. Cochran firstname.lastname@example.org Thomas M. Kelly email@example.com
C.tigroup Inc. '309 Th~rd Avenue 19th Floor New York. NY 10022 BY ELECTRONIC MAIL April 11, 2008 Mr. Robert E. Feldman Executive Secretary Federal Deposit lnsurance Corporation 550 17'~ Street, N.W. Washington,
State Farm Bank, F.S.B. 2015 Annual Stress Test Disclosure Dodd-Frank Act Company Run Stress Test Results Supervisory Severely Adverse Scenario June 25, 2015 1 Regulatory Requirement The 2015 Annual Stress
CLIENT MEMORANDUM June 28, 2010 Collins Amendment Minimum Capital and Risk-Based Capital Requirements The Collins Amendment, originally drafted by the FDIC staff and reflecting views held by Chairwoman
October 2013 U.S. Basel III: Guide for Community Banks Luigi De Ghenghi 1 and Andrew S. Fei 2 Davis Polk & Wardwell LLP Executive Summary: U.S. Basel III is the most complete overhaul of U.S. bank capital
Risk-Based Capital Definition: Risk-based capital (RBC) represents an amount of capital based on an assessment of risks that a company should hold to protect customers against adverse developments. Overview
January 20, 2012 Communications Division Office of the Comptroller of the Currency Mailstop 2 3 Washington, D.C. 20219 Attention: 1557 0081 Secretary Board of Governors of the Federal Reserve System 20
2015 Comprehensive Capital Analysis and Review and Annual Company-Run Dodd-Frank Act Stress Test Results Date: March 5, 2015 TABLE OF CONTENTS PAGE 1. Overview of the Comprehensive Capital Analysis and
NELNET, INC. 121 SOUTH 13TH STREET, SUITE 201 LINCOLN, NE 68508 SLM CORPORATION 300 CONTINENTAL DRIVE NEWARK, DELAWARE 19713 Office of the Comptroller of the Currency Legislative and Regulatory Activities
Summary Supporting Statement for the Recordkeeping and Reporting Requirements Associated with Regulation Y (Capital Plans) (Reg Y-3; OMB No. 700-0342) (Docket No. R-425) (RIN 700-AD77) The Board of Governors
DEPARTMENT OF THE TREASURY Office of the Comptroller of the Currency 12 CFR Parts 3, 5, 6, 165, 167 Docket ID OCC-2012-0008 RIN 1557-AD46 FEDERAL RESERVE SYSTEM 12 CFR Parts 208, 217, and 225 Regulations
Mr. John G. Walsh Acting Comptroller of the Currency Office of the Comptroller of the Currency 250 E Street, S.W. Washington, D.C. 20219 Mr. Robert E. Feldman Executive Secretary Federal Deposit Insurance
MBa MORTGAGE DANKCRS ASSOCIAT Of'.. Honorable Ben S. Bernanke Chairman Board of Governors of the Federal Reserve System 20 1 h Street and Constitution Avenue, NW Washington, DC 20551 (Docket No. R-1460)
Stefan M. Gavell Executive Vice President and Head of Regulatory, Industry and Government Affairs State Street Corporation State Street Financial Center One Lincoln Street Boston, MA 02111-2900 Telephone:
MARKET RISK CAPITAL DISCLOSURES REPORT For the quarter ended March 31, 2013 Table of Contents Section Page 1 Morgan Stanley... 1 2 Risk-based Capital Guidelines: Market Risk... 1 3 Market Risk... 1 3.1
BY ELECTRONIC SUBMISSION Elizabeth M. Murphy Secretary Securities and Exchange Commission 100 F Street, NE Washington, DC 20549-1090 David A. Stawick Secretary Commodity Futures Trading Commission Three
CAPTIVE COMMERCIAL EQUIPMENT ABS ISSUER GROUP Caterpillar Financial Services Corporation CNH Capital LLC Deere & Company Navistar Financial Corporation Volvo Financial Services, a division of VFS US LLC
Legal Update July 15, 2013 Bank Regulators Approve Final Rule to Implement Basel III Capital Requirements in the United States On July 2, 2013, the Board of Governors of the Federal Reserve System ( Board
S Y M P H O N Y A S S E T M A N A G E M E N T 555 California Street Suite 2975 San Francisco CA 94104-1503 Tel: 415,676.4000 Fax: 415.676.2480 www.syinphonyasset.com October 30, 2013 VIA ELECTRONIC MAIL
This document is scheduled to be published in the Federal Register on 06/23/2015 and available online at http://federalregister.gov/a/2015-15412, and on FDsys.gov FEDERAL RESERVE SYSTEM Proposed Agency
Daily Income Fund Retail Class Shares ( Retail Shares ) Money Market Portfolio Ticker Symbol: DRTXX U.S. Treasury Portfolio No Ticker Symbol U.S. Government Portfolio Ticker Symbol: DREXX Municipal Portfolio
O Comptroller of the Currency Administrator of National Banks Washington, DC 20219 July 3, 2001 Interpretive Letter #912 August 2001 12 CFR Part 1 Re: Bank Qualified Mutual Fund Dear [ ]: This letter responds
1001 PENNSYLVANIA AVE., NW SUITE 500 SOUTH WASHINGTON, DC 20004 TEL 202-289-4322 FAX 202-628-2507 E-Mail firstname.lastname@example.org www.fsround.org February 22, 2011 RICHARD M. WHITING EXECUTIVE DIRECTOR AND GENERAL
Securitization Perspectives: Final U.S. Liquidity Coverage Ratio September 10, 2014 Introduction! On September 3rd, the Agencies adopted regulations implementing a liquidity coverage ratio (LCR) requirement
MML Bay State Life Insurance Company Management s Discussion and Analysis Of the 2005 Financial Condition and Results of Operations General Management s Discussion and Analysis of Financial Condition and
Note: The agencies revised this guide on July 18, 2013, to correct an error on page 8, Table 4, Comparison of Risk Weights of the Current Rule with the New Rule. The risk weight under the New Capital Rule
Mr. Brent J. Fields Secretary U.S. Securities and Exchange Commission 100 F Street, NE Washington, DC 20549 Re: Proposed Rules on Pay Versus Performance (Release No. 34-74835; File No. S7-07-15) Dear Mr.
October 27, 2014 The Honorable Richard Cordray Director Consumer Financial Protection Bureau 1700 G Street NW Washington, DC 20006-4702 Monica Jackson Office of the Executive Secretary Consumer Financial
OFFICIAL SEAL OF THE BOARD OF GOVERNORS OF THE FEDERAL RESERVE SYSTEM OFFICIAL LETTERHEAD STATIONERY BOARD OF GOVERNORS OF THE FEDERAL RESERVE SYSTEM WASHINGTON, D.C. 20551 ADDRESS OFFICIAL CORRESPONDENCE
COUNCIL OF FEDERAl HOME LOAN BANKS 2 120 L Street, NW, Suite 208 '-' ashington. DC 20037 20 2.955.000 2 Tel 202.835.1144 Fax www.fhlbanks.com January 31, 20 14 Mr. Robert E. Feldman Legislative and Regulatory
Department of the Treasury Office of the Comptroller of the Currency Docket ID OCC 2013 0020 Board of Governors of the Federal Reserve System Docket No. OP-1474 Federal Deposit Insurance Corporation Proposed
DEPARTMENT OF THE TREASURY Office of the Comptroller of the Currency 12 CFR Part 3 Docket ID: OCC-2010-0003 RIN 1557-AC99 FEDERAL RESERVE SYSTEM 12 CFR Parts 208 and 225 Regulations H and Y; Docket No.
April 30, 2012, Ms. Jennifer J. Johnson Secretary Board of Governors of the Federal Reserve System 20th Street and Constitution Avenue, NW, Washington, DC 20551, Submitted electronically via http://www.regulations.gov,
JPMorgan Chase & Co. 1 Chase Manhattan Plaza, Floor 25 New York, NY 10081 Telephone: (212) 552-1721 Facsimile: (212) 383-8065 Jay.email@example.com Jay N. Soloway Senior Vice President Associate General
STATEMENT OF MARTIN J. GRUENBERG CHAIRMAN FEDERAL DEPOSIT INSURANCE CORPORATION on VOLCKER RULE IMPLEMENTATION before the COMMITTEE ON FINANCIAL SERVICES UNITED STATES HOUSE OF REPRESENTATIVES February
(unaudited) 1. SCOPE OF APPLICATION Basis of preparation This document represents the Basel Pillar 3 disclosures for Canadian Tire Bank ( the Bank ) and is unaudited. The Basel Pillar 3 disclosures included
Last updated: March 26, 2012 Rating Methodology by Sector Non-life Insurance *This rating methodology is a modification of the rating methodology made public on July 13, 2011, and modifications are made
M&T Bank Corporation Resolution Plan December 13, 2013 TABLE OF CONTENTS PUBLIC SECTION... 1 Executive Summary... 1 1. Names of Material Entities... 2 2. Description of Core Business Lines... 3 3. Consolidated
June 9, 2014 Legislative and Regulatory Activities Division Office of the Comptroller of the Currency 400 7 th Street, SW, Suite 3E 218, Mail Stop 9W 11 Washington, DC 20219 Docket ID OCC 2014 0002 Robert
Last Updated: March 26, 2012 Rating Methodology by Sector Life Insurance *This rating methodology is a modification of the rating methodology made public on July 13, 2011, and modifications are made to
Daily Income Fund Retail Class Shares ( Retail Shares ) Money Market Portfolio Ticker Symbol: DRTXX U.S. Treasury Portfolio No Ticker Symbol U.S. Government Portfolio Ticker Symbol: DREXX Municipal Portfolio
November 29, 2010 Communications Division Office of the Comptroller of the Currency Public Information Room Mailstop 2-3 250 E Street, S.W. Washington, D.C. 20219 Attention: 1557-0081 Jennifer J. Johnson
TIAA-CREF Individual & Institutional Services, LLC (A wholly-owned subsidiary of Teachers Insurance and Annuity Association of America) Statement of Financial Condition (Unaudited) Index Page(s) Financial
United of Omaha Life Insurance Company A Mutual of Omaha Company solutions for gift annuity programs sm A Solid Foundation for Growth MUGC8566_0409 not for individual donor use Enhance and Streamline Your
A Technical Overview for Clients and their Advisors MassMutual Whole Life Insurance The product design and pricing process Contents 1 Foreword 2 A Brief History of Whole Life Insurance 3 Whole Life Basics
CITIGROUP INC. BASEL II.5 MARKET RISK DISCLOSURES AS OF AND FOR THE PERIOD ENDED MARCH 31, 2013 DATED AS OF MAY 15, 2013 Table of Contents Qualitative Disclosures Basis of Preparation and Review... 3 Risk
BMO Financial Corp. and BMO Harris Bank N.A. 206 Comprehensive Capital Analysis and Review Dodd-Frank Act Company-Run Stress Test Supervisory Severely Adverse Scenario Results Disclosure June 23, 206 Overview
January 18, 2006 Robert E. Feldman Executive Secretary Attention: Comments/Legal ESS Federal Deposit Insurance Corporation 550 17th Street, NW Washington, DC 20429 Public Information Room Office of the
Mutual of Omaha Insurance Company and Subsidiaries Executive Summary and Analysis of Financial Condition as of September 30, 2015 and December 31, 2014 and Results of Operations for the Nine Months Ended
Summary Prospectus October 30, 2015 Brown Advisory Strategic Bond Fund Class/Ticker: Institutional Shares / (Not Available for Sale) Before you invest, you may want to review the Fund s Prospectus, which
DEPARTMENT OF THE TREASURY Office of the Comptroller of the Currency 12 CFR Part 46 [Docket ID OCC-2011-0029] RIN 1557-AD58 Annual Stress Test AGENCY: Office of the Comptroller of the Currency ( OCC ).
Louisiana Bankers A5555 Baton Phone S SBankers ORouge, 225 C I387-3282 A TAvenue LA I70808 O N Fax 225 343-3159 December 10, 2013 Legislative and Regulatory Activities Division Office of the Comptroller
Checklist for Credit Risk Management I. Development and Establishment of Credit Risk Management System by Management Checkpoints - Credit risk is the risk that a financial institution will incur losses
Supporting Statement for the Reporting, Recordkeeping, and Disclosure Requirements Associated with Regulation YY (Enhanced Prudential Standards) (Reg YY; OMB No. 7100-0350) Annual Company-Run Stress Test
Vol. 77 Thursday, No. 169 August 30, 2012 Part II Department of the Treasury Office of the Comptroller of the Currency 12 CFR Parts 3, 5, 6, et al. Federal Reserve System 12 CFR Parts 208, 217, and 225
Federal Reserve Issues Regulations for Savings and Loan Holding Companies August 19, 2011 Pursuant to Section 312 of the Dodd-Frank Wall Street Reform and Consumer Protection Act (the Dodd-Frank Act ),
February 25, 2013 Monica Jackson Office of the Executive Secretary Consumer Financial Protection Bureau 1700 G Street, NW Washington, DC 20552 Re: Docket No. CFPB-2013-0002 Proposed Amendments to the Ability-to-Repay
Robert G. Rowe, III Vice President/Senior Counsel Center for Regulatory Compliance Phone: 202-663-5029 E-mail: firstname.lastname@example.org April 1, 2014 Monica Jackson Office of the Executive Secretary Bureau of Consumer
The Goldman Sachs Group, Inc. and Goldman Sachs Bank USA 2015 Annual Dodd-Frank Act Stress Test Disclosure March 2015 2015 Annual Dodd-Frank Act Stress Test Disclosure for The Goldman Sachs Group, Inc.
MUTUAL OF OMAHA Investor Presentation July 2014 Forward-Looking Statements This document contains certain forward-looking statements about Mutual of Omaha Insurance Company ( Mutual of Omaha ) and certain
BOARD OF GOVERNORS OF THE FEDERAL RESERVE SYSTEM Date: April 19, 2016 To: Board of Governors From: Staff 1 Subject: Re-proposed joint rules implementing the incentive compensation requirements of the Dodd-Frank
Supporting Statement for the Consolidated Financial Statements for Holding Companies (FR Y-9C; OMB No. 7100-0128) Summary The Board of Governors of the Federal Reserve System, under delegated authority
national community investment fund May 17, 2013 Legislative and Regulatory Activities Division Office of the Comptroller of the Currency Mail Stop 9W-11 400 7th street, SW Washington DC 20219 Docket ID
U.S. Banking Law and the FBO What You Need to Know U.S. Regulatory/Compliance Orientation Program Institute of International Bankers Derek M. Bush December 2, 2015 2015 Cleary Gottlieb Steen & Hamilton