2010-06-08
The South Dakota Division of Banking issued this memorandum to clarify the impact of Financial Accounting Standard 166 on state-chartered banks. The guidance mandates that participations sold after January 1, 2010, must be sold on a pro-rata basis to qualify as participating interests for balance sheet derecognition. It further explains that non-pro-rata participations remain on the bank’s balance sheet as secured borrowings and are aggregated toward the bank’s legal lending limit, potentially affecting capital and lending limit relief.