Circular No. 11400
November 27, 2001


To All Depository Institutions and Others Concerned in the Second Federal Reserve District:

In a Federal Register notice (pdf - 43kb), the Federal Reserve Board has requested comments by December 27, 2001, on a proposal to amend the Fed’s risk-based capital guidelines to clarify that deferred tax assets in excess of the allowable amount (disallowed deferred tax assets) are included in the items that are deducted from tier 1 capital for the purpose of determining the maximum allowable amount of tier 2 capital that a banking organization may include in qualifying total capital and the maximum allowable amount of term subordinated debt and intermediate-term preferred stock that may be treated as supplementary capital.

Questions on this matter may be directed, at this Bank, to Kim Olson, Assistant Vice President, Policy and Analysis Function.

William L. Rutledge
Executive Vice President