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December 17, 2018

The Comptroller of the Currency, Federal Reserve Board and FDIC proposal allowing "advanced-approaches" banking organizations (i.e., those with $250 billion or more in total consolidated assets, or $10 billion or more in on-balance sheet foreign exposure) to use an alternative approach for calculating derivative exposures under regulatory capital rules was published in the Federal Register. Comments must be received before February 15, 2019. As previously covered, the proposed approach - the standardized approach for counterparty credit risk ("SA-CCR") - would replace the current exposure