On June 7, 2012, the Federal Reserve Board (“Fed”) released three interagency proposed rules that would revise and replace the current capital rules of the Fed, Office of the Comptroller of the Currency (“OCC”) and Federal Deposit Insurance Corporation (“FDIC”). In particular, the proposals would implement in the U.S. the Basel III capital framework agreed to by the Basel Committee on Banking Supervision (“Basel III: A Global Regulatory Framework for More Resilient Banks and Banking Systems).