WBA recently submitted comments in support of proposed simplifications to capital rules, focusing specifically on the treatment of certain assets and capital instruments, including trust preferred securities (TruPS), and the new definition of high volatility acquisition, development, or construction (HVADC). Among other things, WBA strongly urged the Agencies to completely exclude from the deduction from capital grandfathered existing TruPS held by banks. In addition, WBA urged that the current prospective suspension of HVCRE assets be finalized and the proposed HVADC not be implemented, but suggested alternatives if the Agencies were unwilling to adopt our initial request. 

A copy of the comment letter can be found here.