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June 2022

The History of Supervisory Expectations for Capital Adequacy: Part I (1863-1983)

This publication is part of:

Collection: Moments in History


As the supervisor of national banks since 1863, the Office of the Comptroller of the Currency (OCC) has placed significant importance on the quantity and quality of capital when evaluating the safety and soundness of banks. The OCC's focus on capital was apparent in the first communication by Comptroller Hugh McCulloch to newly chartered national banks in December 1863. Those policy questions remain today: what are the correct elements to include in a measure of capital, and how should that capital be evaluated in the context of the bank's activities?


Roger Tufts and Paul Moloney