OMB files this comment in accordance with 5 CFR 1320.11( c ). This OMB action is not an approval to conduct or sponsor an information collection under the Paperwork Reduction Act of1995. This action has no effect on any current approvals. If OMB has assigned this ICR a new OMB Control Number, the OMB Control Number will not appear in the active inventory. For future submissions of this information collection, reference the OMB Control Number provided. Pursuant to 5 CFR 1320.11(c), OMB files this comment on this information collection request (ICR). In accordance with 5 CFR 1320, OMB is withholding approval at this time. The agency shall examine public comment in response to the NPRM and will describe in the preamble of the final rule how the agency has maximized the practical utility of the collection and minimized the burden. The next submission to OMB must include the draft final rule.
table that charts list comparision
Inventory as of this Action
Requested
Previously Approved
01/31/2013
36 Months From Approved
03/31/2013
1,251
0
1,251
821,640
0
821,640
0
0
0
The OCC, FRB, and FDIC have issued three notices of proposed rulemaking that would revise and replace their capital rules. The first (Basel III NPR 1) would revise their risk-based and leverage capital requirements consistent with agreements reached by the Basel Committee on Banking Supervision (BCBS)in Basel III - A Global Regulatory Framework for More Resilient Banks and Banking Systems. The second (Basel III NPR 2) would revise and harmonize their rules for calculating risk-weighted assets to enhance risk sensitivity and address weaknesses identified in recent years. The last (Basel III NPR 3) would revise the advanced approaches risk-based capital rules consistent with Basel III and other changes to the BCBS's capital standards.
The qualification process/requirements and ongoing qualification for Basel III and Basel II are substantially the same. The significantly higher estimates for Basel II are due to the fact that, at the time the rule was adopted, banks had to create from scratch a system of rating every exposure. In addition, the OCC had no experience with assisting them and providing clear expectations. With Basel III, five years later, few banks are coming in. Banks coming now in have an easier time coming up to speed, as we are able to assist them better and provide a clear set of expectations. Therefore, the replacement of the Basel II qualification process/requirements and ongoing qualification with that of Basel III resulted in an adjustment of -751,325 hours. The addition of the regulatory capital and standardized approach provisions resulted in a program increase (agency discretion) of +124,704 hours. This results in an overall decrease in burden of -626,621.50 hours.
On behalf of this Federal agency, I certify that the collection of information encompassed by this request complies with 5 CFR 1320.9 and the related provisions of 5 CFR 1320.8(b)(3).
The following is a summary of the topics, regarding the proposed collection of information, that the certification covers:
(i) Why the information is being collected;
(ii) Use of information;
(iii) Burden estimate;
(iv) Nature of response (voluntary, required for a benefit, or mandatory);
(v) Nature and extent of confidentiality; and
(vi) Need to display currently valid OMB control number;
If you are unable to certify compliance with any of these provisions, identify the item by leaving the box unchecked and explain the reason in the Supporting Statement.
Basel III (December 21).docx
Minimum Regulatory Capital Ratios, etc. - Recordkeeping (Basel III NPR 1)