Key takeaways

• The Office of Comptroller of the Currency of the U.S. Treasury Department and the Board of Governors of the Federal Reserve System issued an interim final rule amending the definitions of “qualifying master netting agreement” (“QMNA”) under the agencies’ regulatory capital rules and liquidity coverage ratio rule, as well as the lending limits rule applicable to national banks and federal savings associations. The interim final rule also amends the definitions of “collateral agreement,” “eligible margin loan,” and “repo-style transaction” under the capital rules.
• These amendments are designed to ensure that the U.S. regulatory capital, liquidity, and lending limits treatment of certain financial contracts not be affected by the implementation of special resolution regimes in foreign jurisdictions or by the ISDA 2014 Resolution Stay Protocol.
• The interim final rule, which applies to banking organizations other than state nonmember banks, will be effective as of January 1, 2015. Comments are due by March 3, 2015.