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FEDERAL RESERVE BANK
OF NEW YORK

Circular No. 9124
August 6, 1981

A M E N D M E N T TO REG ULATIO N K
Capital R equirem ents of E d ge Corporations
To All Member Banks, Edge and Agreement Corporations, and Bank Holding
Companies in the Second Federal Reserve District, and Others Concerned:

The Board of Governors of the Federal Reserve System has amended its
Regulation K, “International Banking Operations,” in order to perm it the inclusion of
certain subordinated notes and debentures in the determination of capital adequacy of
Edge Corporations.
Enclosed is a copy of the amendment. Questions regarding this m atter may be
directed to our Foreign Banking Applications Department (Tel. No. 212-791-5878 or
5881).




A nthony M. S olomon,
President.

B oard of G overnors of the F ed eral R eserve System
IN T E R N A T IO N A L BA N K IN G O PERA TIO N S

AMENDMENT TO REGULATION K
(effective J u ly 29, 1981)

Capital Requirements of Edge Corporations

AGENCY:

Board

of

ACTION:

Final

rule.

SUMMARY:

The

C.F.R.

§

within

the

Board

211.6(d))

determining

of

section
50

of

EFFECTIVE

FOR

Radish,
of

the

of

Federal

persons
of

its

"Capital
and

and

capital

In

order

capital
may

also

or

means

purposes.

to

the

[Enc. Cir. No. 9124]




of

R.

the

For

(1 2

purpose

purposes

amount

as

to

defined

Dahl,

Regulation

Washington,

in

its

D.

211.6(d)

in

an

no

in

an

the

of

amount

more

section

paid-in

and

but

that
is

In

K

Michael

less

7

the

Edge

relation

Edge

nonaffiliated
per

provides

capital

an

in

an

from

than
K

include

imposes

adequate

addition,

Regulation

not

or

Governors

section,

States

unimpaired

does

Director,

20551.

that

not

of

Regulation

United

of

Board

C.

activities.
in

Associate

(202/452-2726);

Under

amount

211.2(b)

profits

however,

of

provide

Such

the

as

liabilities

the

has

liabilities

as

banks

capital

D

with

and

not

(12

Regulation

Corporations
Board

member

must

Regulation

Board's

Edge

such

permits

liabilities

Board's

requirements,
include

for

K

debentures

and

cent
that,
surplus,

proceeds

of

debentures."

Board,

217.1(f)

and

211.2(b)).

Corporations.

capital

subordinated

of

could

(202/452-3428),

deposits

Section

surplus

notes

204.2(a)(1)
section

accepts

Regulation
notes

solely

surplus

Frederick

Section

Edge

character

undivided

The

adequacy

System,

capitalized

maintain

and

long-term

be

and

§

and

Division

on

assets.

includes

CONTACT:

Legal

of

Corporations.

debentures

C.F.R.

System.

1981.

INFORMATION:

that

must
risk

29,

Reserve

must

scope

Corporation

(12

surplus"

capital

Supervision

requirements

Corporation

K

211.6(d)

Edge

and

Reserve

subordinated

and

of

notes

total

INFORMATION

Attorney,

capital

the

July

section

"capital

such

Federal

certain

adequacy

the

Banking

SUPPLEMENTARY

to

of

the

amended

of

Regulation

DATE:

FURTHER

Division

cent

of

include

capital

211.6(d),

per

211.2(b)

has
to

definition

of

than

Governors

be

to

(12

more

determined
capital

§

§

under

section

Edge

surplus

or

217.1(f)).

flexibility

and

capital

204.2(a)(1)),

C.F.R.

that

certain

for

"deposits"

C.F.R.
Q

include

surplus

to

meet

Corporations
for

capital

(OVER)

L.

adequacy

purposes.

importance
tions;

an

as

The

such

capital

non-debt

to

capital

an

Edge

of

the

like

and

mined

that

the

§

with

should

as

respect

553

of

interest,

notes,

however,

will

and

to

the
that

action

this

an

Comments

determining
on

that

the

definition

the

adequacy

used

with

of

bank

25(a)

to

the

Effective
is

amended

as

banks'

Edge

action
of

is

taken

211.6—

29,

1981,

LENDING

(d)

character

per
or

as

in

cent

in
of

be

of

a

the

United

Edge

of

5
in

Board

Institutions

Any

for

of

bank

including

banks

1981.

also

the

definition

the

deter­

U.S.C.

The

Financial

Board

Corpora­

has

that,

agencies,

31,

the

(12

they

the

supervise.

change

in

determining

affect

Board's

U.S.C.

211

AND

*

an

for

that

of

12

CAPITAL

*

is

activities.
its

capital

assets.

in

member

consolidated

funds

Part

LIMITS
*

amount

its

risk

included

for

an

banking,

debentures,

may

a

in

to

Act

the

definition

authority

§§

under

611-631).

C.F.R.

Chapter

II

For

amount

this

not

determining

bank;
basis

risk
other

States,

than

United

the

exceed

shall

cash,

States

of

an

Edge

be

not

subordinated

50

per

cent

adequacy
be

Corporation

relation

shall

purpose,

to

Edge
in

case

surplus

capital

assets

An

adequate

In
and

REQUIREMENTS

*

Capitalization.

capitalized

and

and

in

the

would

pursuant

Reserve

*

engaged

capital

by

on

Board

provisions

broadened

August

approval

Corporations.

Federal

July

by

adopted

section

immediately.

capital

con­
amount

follows:

§

be

due

of

be

the

liability

the

the

Federal

a

to

restriction

unnecessary

the

not
of

debt

the

Corpora­

capital.

regulatory

adequacy
are

a

effective

bank

capital

member

respect

This
section

the

proposal

of

are

comment

Federal

bank

participation

be

will
cent

without

operations,

far

of

in

member

stress
Edge

pursuant

capital

1981,

proposed

Board,

as

17,

the

per

subordinated

June

Council
use

no

removes

action

capital

50

to

for

liabilities

exceed

efficient

should

Examination
for

D,

of

public

rule

debt

qualify

more

continue
capital

Furthermore,

treatment

this

will

non-debt

they

surplus.

permit

notice

public

extent

Regulation

the

Inasmuch
tions

of

subordinated

Corporation

Board,

however,

level

the

and

2 0 4 . 2 ( a ) ( 1 ) (vii)(C)
of

Board,

adequate

therefore,

sidered
of

of

in

deemed

amounts

due

Government

to

of

the
be

from

to

shall

the

By

order

effective




of
July

the
29,

Board

of

Governors

of

less

than

capital

all

7

notes

non-debt
same

capital,

manner
assets

banking

securities,

the

all

Corporation

and

Federal

Federal

Reserve

1981.

William W. Wiles
Secretary of the Board

on

institutions

sold.

System,

at

scope

times