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OCC Revises Subordinated Debt Licensing Manual
On Tuesday, November 7, 2017, the OCC issued the “Subordinated Debt” booklet of the Comptroller’s Licensing Manual, replacing the booklet issued in November 2003 and the related guidance (OCC Bulletin 2015-22) issued April 3, 2015. The revised booklet incorporates updated requirements for issuing subordinated debt and including it as tier 2 capital, as well as revised sample notes for national banks and new sample notes for federal savings associations (FSA). These updates are the result of the integration of the functions of the Office of Thrift Supervision into the OCC in 2011 and the issuance of revised regulations (12 CFR 5) that became effective July 1, 2015, addressing subordinated debt for national banks and FSAs.