With James Croke
The Office of the Comptroller of the Currency (OCC), the Board of Governors of the Federal Reserve System (Board), the Federal Deposit Insurance Corporation (FDIC), and the Office of Thrift Supervision (OTS) (collectively, "the Agencies") have jointly issued an advance notice of proposed rulemaking (the "ANPR") that discusses various proposed revisions to the existing U.S. risk-based capital framework that would increase the number of risk-weight categories, permit greater use of exter