On March 18, the extended comment period ended for the
Standardized Approach for Calculating the Exposure Amount of
Derivative Contracts ("SA-CCR") rule (the "Proposed
Rule")1 proposed by the Federal Reserve Board
("Board"), the Federal Deposit Insurance Corporation
("FDIC"), and the Office of the Comptroller of the
Currency ("OCC" and together with the Board and the FDIC,
the "Agencies"). SA-CCR would, in some cases, supplant
the calculations currently used by banking organizations for
derivatives under the existing regulatory capital rule,2
and may have significant implications for commercial
end-users.
A total of 54 public comments were submitted from a wide range
of respondents, including commercial end-users and related trade
associations, major banks and industry groups, and the Commodity
Futures Trading Commission. A substantial comment letter was also
jointly submitted by the International Swaps and Derivatives
Association, Inc., the Securities Industry and
