Regulatory Alerts2021-03-22 | 2021-05443Regulatory Capital Rule: Emergency Capital Investment Program
The OCC, Federal Reserve Board, and FDIC issued an interim final rule amending their capital regulations to classify Treasury’s Emergency Capital Investment Program instruments as regulatory capital. The rule designates ECIP senior preferred stock as additional tier 1 capital and subordinated debt as tier 2 capital, while clarifying that Treasury-imposed covenants will not unduly restrict national bank authority or agency supervision. This regulatory adjustment facilitates timely capital investments in low- and moderate-income community financial institutions, enabling them to sustain lending and support underserved communities amid the economic impacts of the COVID-19 pandemic.
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