06.30.2025

US Agencies Propose Modifying Regulatory Capital Standards

06.30.2025
US Agencies Propose Modifying Regulatory Capital Standards

The federal bank regulatory agencies requested comment on a proposal to modify certain regulatory capital standards to reduce disincentives for banking organizations to engage in lower-risk activities and promote the smooth functioning of U.S. Treasury markets.

Banking organizations are subject to both risk-based and leverage capital requirements. Risk-based capital requirements vary based on the risks of individual exposures, imposing lower capital requirements, for example, on a Treasury security with lower risk than on a corporate bond with higher risk. Leverage capital requirements, by design, treat all exposures equally. A leverage capital requirement that is generally higher than risk-based capital requirements can discourage banking organizations from engaging in low-risk activities, such as U.S. Treasury market intermediation.

The proposal would modify certain leverage capital standards applicable to the largest and most systemically important banking organizations so that they serve as a backstop to risk-based capital requirements and do not discourage these banking organizations from engaging in low-risk activities. In particular, the proposal would set the enhanced supplementary leverage ratio for both bank holding companies and their depository institution subsidiaries so that it is based on a banking organization’s overall systemic risk.

The agencies anticipate that the amount of overall capital that banking organizations maintain would generally stay the same as a result of this proposal. In aggregate, the proposal would reduce tier 1 capital standards for affected bank holding companies by less than two percent. Although certain depository institution subsidiaries could see greater reductions, that capital generally would not be available for distribution to external shareholders given the restrictions that apply at the bank holding company level.

The proposal would also make conforming changes to other regulations that are tied to the enhanced supplementary leverage ratio, such as total loss-absorbing capacity and long-term debt requirements.

Comments on the proposal are due by August 25, 2025.

Board memo (PDF)

Federal Register notice: Regulatory Capital Rule: Modifications to the Enhanced Supplementary Leverage Ratio Standards for U.S. Global Systemically Important Bank Holding Companies and Their Subsidiary Depository Institutions; Total Loss-Absorbing Capacity and Long-Term Debt Requirements for U.S. Global Systemically Important Bank Holding Companies (PDF)

Statement from Chair Powell

Statement from Vice Chair for Supervision Bowman

Statement from Governor Barr

Statement from Governor Kugler

Statement from Governor Waller

Open Board Meeting on June 25, 2025

Source: Federal Reserve

The FDIC Deregulating Wall Street Banks by Lowering Capital Makes Future Crashes, Bailouts and Main Street Misery Inevitable

Dennis KelleherCo-founder, President and CEO of Better Markets, issued the following statement on the Federal Deposit Insurance Corporation (FDIC) Board’s support for proposed changes to the enhanced supplementary leverage ratio capital requirement:

“Letting ideology, Wall Street’s CEOs, and the industry’s special interests drive decisions, rather than facts, merit, and the public interest, the FDIC and the Fed are marching in lockstep to mindlessly deregulate the industry, just as they did in the years before the 2008 crash. While denying reality, making up your own facts, listening only to people who already agree with you, and claiming superficial pretexts to justify your conduct are in vogue today, that won’t stop the next catastrophic crash from happening – in fact, it makes that crash inevitable. That is what the FDIC, the Fed, the other financial regulators and the Trump administration more broadly are doing.

“The only thing standing between a failing bank, a financial crisis, a taxpayer bailout, and economic and human catastrophe is the amount of capital a bank has to absorb its own losses. The proposal by the FDIC to significantly lower capital requirements repeats the Fed’s dereliction of duty. These proposals would ensure that the largest, most dangerous Wall Street megabanks are much more likely to fail and result in taxpayer bailouts and depositor losses when they do fail. That, along with the other deregulatory actions by the FDIC (detailed here and here), will bring the country more quickly towards the next significant financial crash.

“The proposal would reduce capital requirements by an astonishing 27 percent at the depository institution subsidiaries of the global systemically important banks (GSIBs). There is no possible justification for the FDIC supporting this. Protecting the Deposit Insurance Fund and the savings accounts of Main Street Americans is the core mission of the FDIC, but this proposal is in direct opposition to fulfilling that mission and is clear evidence that the FDIC is putting Wall Street interests above the best interests of Main Street Americans. Moreover, the pretext for the proposal, supporting Treasury market functioning, is not the responsibility of the FDIC, and even that pretext is rebutted by research from the Fed itself. Finally, and to make the situation worse, the FDIC is effectively ceding its regulatory authority to the Fed by anchoring its regulations to the so-called GSIB surcharge, a separate regulation primarily controlled by the Fed.

“Moreover, the FDIC’s decision disadvantages community banks, the primary set of banks under FDIC authority. The largest banks in the U.S. already have as much leverage as the largest hedge funds, and in many cases, much higher than levels allowed for community banks. The changes proposed today will allow for additional increases in large bank leverage, while at the same time, exposing large banks, community banks, and the economy to systemic risk. That’s great for the Wall Street megabank CEOs and shareholders because more leverage means a higher return on equity, higher shareholder payouts, and higher executive bonuses. But it’s bad for hardworking Main Street Americans and community banks because lower capital means more bank failures, financial crises, and taxpayer bailouts.

“The FDIC’s action, and the Fed’s action, is part of a more comprehensive plan to deregulate the banking industry, which is undermining the financial regulatory agencies’ credibility and integrity. The capital framework proposed after the 2008 crash was designed to prevent the biggest, most dangerous banks from engaging in highly leveraged, high-risk activities that threaten the financial stability and economy of our country. That framework had two mutually complementary aspects that ensured banks would have enough capital and not require taxpayer bailouts. One part was based on risk, and the other was based on the overall amount of leverage at the bank. These two requirements were designed to work together to prevent Wall Street’s megabanks from endangering Main Street families. The FDIC’s proposal undermines this two-part approach, lowering the leverage requirement and making bank failures, crises, and bailouts much more likely.

“Bank depositors, taxpayers, and all Main Street Americans deserve better from FDIC leadership. Shamefully, the FDIC’s leadership is following along with the deregulatory plan laid out by the Trump Administration at the expense of the American taxpayers and savers—the exact people who the FDIC is supposed to be protecting.”

Source: Better Markets

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