Report Regarding Differences in Accounting and Capital Standards Among the Federal Banking Agencies (Federal Reserve Board)

Summary

• As of September 30, 2025, the federal banking agencies identified no material differences among accounting standards applicable to insured depository institutions.p.1
• Pre-sold construction loans where a purchaser terminates the contract are disqualified from receiving a 50 percent risk weight and receive a 100 percent risk weight.p.2
• Under section 5(t)(2)(B) of HOLA, savings associations are required to maintain tangible capital in an amount not less than 1.5 percent of total assets.p.5
• Under the Prompt Corrective Action framework, institutions are considered critically undercapitalized if their tangible equity falls below 2 percent of total assets.p.5
• An appropriate federal banking agency must generally appoint a receiver within 90 days after an institution becomes critically undercapitalized.p.5
• Enhanced supplementary leverage ratio standards require certain bank holding companies to exceed a 5 percent ratio and subsidiary institutions to meet a 6 percent ratio.p.5
• The OCC applies enhanced supplementary leverage ratio standards to subsidiary institutions of top-tier BHCs with more than $700 billion in total assets or more than $10 trillion in assets under custody.p.5

Key insights

1. The agencies identified no new material differences in capital standards applicable to insured depository institutions compared to their previous report.p.2
2. The Board's capital rule allows cash dividend payments to be paid out of related surplus, though separate regulatory restrictions limit this practical impact to bank holding companies and savings and loan holding companies.p.3
3. The FDIC's capital rule explicitly requires supervised institutions to deduct examiner-identified losses from common equity tier 1 capital elements.p.3
4. Parent savings associations must deduct investments in and extensions of credit to subsidiaries engaged in activities impermissible for national banks from parent capital.p.4
5. The OCC and FDIC include a regulatory 1.5 percent tangible capital ratio requirement for savings associations, whereas the Board's framework does not apply to savings associations.p.5
6. Rule text for enhanced supplementary leverage ratio applicability differs among agencies, as the OCC uses asset thresholds of $700 billion in total assets or $10 trillion in assets under custody.p.5