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OCC Publishes Revised "Subordinated Debt" Booklet

The Office of the Comptroller of the Currency ("OCC") published a revised "Subordinated Debt" booklet of the Comptroller's Licensing Manual. The revised booklet replaces the booklet of the same title that was issued in November 2003, and covers the revised regulations (12 C.F.R. 5) that became effective on July 1, 2015. The booklet contains (i) updated requirements for issuing subordinated debt and including it as tier 2 capital, and (ii) a clarification regarding the policies and procedures for issuing subordinated debt and getting it approved as tier 2 capital.

The booklet includes specific requirements and procedures related to subordinated debt, including regulatory capital requirements, lending limits, information on applications for approval, and other relevant guidance. The booklet includes links to informational resources that may be useful throughout the subordinated debt issuance process.

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