Why BHCs Should Focus On Capital

Law360, New York (October 8, 2010, 11:52 AM EDT) -- On Sept. 1, 2010, Comerica Inc. announced that its subsidiary Comerica Capital Trust II intends to fully redeem all $500 million of its 6.576 percent trust preferred securities (TPS).

This announcement illustrates the need for bank holding companies (BHCs) to focus on long-term capital planning in light of the Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010.

A section of the act, commonly referred to as the Collins amendment,[1] mandates significant changes to existing risk-based capital requirements, one primary effect of which is to...
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