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BankNet

BankNet
More resources for national banks

Interpretive Letters

Credit Risk and Capital Charge for the Government Card Program (Interpretive Letter 1038, September 2005) 
Covers capital treatment for unused portions of lines of credit on cards issued to Federal employees

Home Equity Lines of Credit: Securitization (Interpretive Letter 1035, August 2005)
Covers banks’ securitization of their home equity lines of credit

Intangible Assets (Interpretive Letter 990, April 2004)
Covers merchant processing intangible assets relative to separability, valuation, and marketability criteria

Loans for Margin Stock (Interpretive Letter 1104, December 2008)
Covers use of an alternative approach to calculating risk-based capital requirements on loans for margin stock

Multifamily Residential Property (Interpretive Letter 989, April 2004)
Covers treatment of actual operating income of a multifamily residential property under risk-based capital guidelines 

Multipurpose Loan Commitments (Interpretive Letter 1057, May 2006)
Covers the capital treatment of a multipurpose loan commitment

Risk-Based Capital: Charge for Securities Lending (Interpretive Letter 1066, August 2006)
Covers use of an alternative calculation for a risk-based capital charge for certain securities lending transactions

Risk-Based Capital: Liquidity Facility (Interpretive Letter 1099, May 2007)
Covers application of the asset quality test to a liquidity facility under risk-based capital rules for asset-backed commercial paper

Risk-Based Capital: ICE US Trust, LLC (Interpretive Letter 1116, May 2009) 
Addresses risk-based capital treatment for bank exposures to ICE US Trust, LLC, a limited purposed trust company

Risk-Based Capital: Structured Second Mortgages (Interpretive Letter 1058, May 2006)
Addresses the risk-based capital treatment of structured second mortgages

Service Costs as Dividends (Interpretive Letter 1067, August 2006) 
Covers when service costs constitute a dividend under 12 USC 60

Synthetic Securitizations (Interpretive Letter 988, April 2004)
Addresses a request for a risk-based capital interpretation for synthetic securitizations and a government-sponsored enterprise transaction

Value at Risk: Securities and Conduit Securities Lending (Interpretive Letter 1105, December 2008)
Covers risk-based capital treatment for certain securities lending transactions