Thrift holding companies are not subject to any quantitative capital guidelines or leverage limitations. Accordingly, such companies do not calculate risk-based assets on a consolidated basis at the holding company level. There are a number of thrift holding companies that have considerable financial services activities at the holding company level.
The Capital Purchase Program ("CPP") provides that a financial institution can receive senior preferred securities equal to no less than 1% or more than 3% of risk-weighted assets (subject to an overall cap of $25 billion).
The Office of Thrift Supervision ("OTS"), the federal regulator of holding companies over federal savings banks and state savings banks that have made a 10(l) election, has been concerned that thrift holding companies may be overstating their risk-weighted assets. When a thrift holding company's consolidated risk-weighted assets significantly exceed the risk-weighted assets of the subsidiary financial institution, the OTS is requiring more information in order to deem the CPP application to be informationally complete. Specifically, the holding company must detail how it "risk weights" its assets and that it is using a methodology that is consistent with the thrift financial report instructions. The OTS is considering whether to require an independent third-party verification in such circumstances (the OTS has not required such a verification to date).