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Implications of an Early Extension of a 364-day Credit Facility

Because banks receive favorable capital treatment when a credit facility’s tenor is shorter than one year, lenders increasingly offer financing with 364-day tenors and uncommitted extension option terms of up to 364 days. In...more

Time Warp? Proposed Basel Endgame Reporting Requirements Released Before Final Rule

On January 26, 2024, the US federal banking regulators announced proposed reporting changes to implement the Basel III Endgame requirements. This may come as a surprise to the many banking organizations and others, who only...more

Comment Period for Basel III Endgame Proposal Closes

On January 16, 2024, the comment period closed for the US banking regulators’ Basel III Endgame proposal. Nearly 200 comment letters were submitted from the financial sector, commercial user, and the general public....more

Cart Before Horse: Banking Regulators Extend Comment Period and Launch Data Collection for Basel Endgame

On October 20, 2023, the US federal banking regulators announced that they were extending the period for public comment to January 16, 2024 for both the (i) Basel Endgame proposal to significantly revise the risk-based...more

The Final Stretch: Securitization in the US Under the Proposed Basel III Endgame Rules

On July 27, 2023, the US banking regulators issued a notice of proposed rulemaking (the “NPR”) to revise significantly the risk-based capital requirements applicable to large banks and to banks with significant trading...more

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