News & Analysis as of

Federal Reserve Banks Capital Requirements

Cadwalader, Wickersham & Taft LLP

Midyear Momentum, July 2025 - Federal Reserve Releases Results of Stress Tests

On June 27, the Federal Reserve Board issued the aggregate and individual results of the supervisory stress test (also known as the Dodd-Frank Act Stress Test or DFAST, as these tests are required by Section 165 of the...more

Skadden, Arps, Slate, Meagher & Flom LLP

US Banking Regulators Propose Changes to the Enhanced Supplementary Leverage Ratio for US GSIBs

On June 27, 2025, the Federal Reserve approved a proposal to recalibrate a key capital requirement applicable to the largest U.S. banking organizations (known as global systemically important banks (GSIBs)). - The proposal...more

Latham & Watkins LLP

Banking Regulators Propose to Ease Enhanced Supplementary Leverage Ratio for Large US Banks

Latham & Watkins LLP on

The proposal aims to free up large bank balance sheets and promote US Treasury market intermediation, which the current regulations may hinder....more

Orrick, Herrington & Sutcliffe LLP

Fed releases annual stress test results for 2025

On June 27, the Fed released the results of its annual supervisory stress test, evaluating how large banks would perform under hypothetical adverse economic conditions. The Fed conducts stress tests annually as part of its...more

Kohrman Jackson & Krantz LLP

Federal Reserve Signals Shift Toward Pragmatic Banking Regulation

With a focus on pragmatic and risk-based oversight, new leadership at the Federal Reserve signals a shift in the regulatory landscape for U.S. banks. Earlier this month, the Senate confirmed Federal Reserve Governor Michelle...more

Cadwalader, Wickersham & Taft LLP

Rules in Motion May 2025 - Cadwalader Capital Corner

On an aggregate basis, banking industry net revenue improved in Q1 despite flattish NIM on near-record non-interest income and expense improvements....more

Goodwin

Consequences of Forming or Acquiring a Depository Institution

Goodwin on

This second installment in a series of insights on bank charter considerations describes the consequences of operating through an insured depository institution charter, including capital requirements, supervision and...more

Cadwalader, Wickersham & Taft LLP

May Market Moves, May 2025 - Modifications to the Capital Plan Rule and Stress Capital Buffer Requirement – Notice of Proposed...

The Federal Reserve Board has requested comment on a proposal designed to reduce the volatility of the capital requirements stemming from its annual stress tests. The proposal would achieve this primarily by averaging the...more

Orrick, Herrington & Sutcliffe LLP

Fed report explores risk sensitivity benefits in bank capital requirements

On March 28, the Fed released a report titled “Outlining and Measuring the Benefits of Risk Sensitivity in Bank Capital Requirements” evaluating the integration of risk regarding bank capital requirements. The report asserted...more

Patomak Global Partners

Federal Reserve Board Considering Significant Bank Stress Test Changes

In December 2024, the Federal Reserve Board (the “Board”) announced that they will be seeking public comment on “significant changes to improve the transparency of its bank stress tests and to reduce the volatility of...more

Katten Muchin Rosenman LLP

Basel III Endgame: Will Banks Have to Increase Their Capital Requirements?

On Tuesday, September 10, the Federal Reserve announced a reproposal of the much discussed and awaited Basel III Endgame. However, before we dive into the reproposal, it is important to take a step back and look at how we got...more

Orrick, Herrington & Sutcliffe LLP

Fed’s 2024 stress test results show a robust banking system

Recently, the Fed released the 2024 Federal Reserve Stress Test Results and found that the tested banks have “sufficient capital” to absorb losses and weather a recession while staying above minimum capital requirements. The...more

Ballard Spahr LLP

Banking and Non-Banking Industries Voice Concern Over Basel III Endgame Proposal’s Potentially Significant Negative Impact on...

Ballard Spahr LLP on

On September 18, 2023, the Federal Reserve, Federal Deposit Insurance Corporation, and the Office of the Comptroller of the Currency jointly published and sought comments on a proposal to implement new, standardized capital...more

Cadwalader, Wickersham & Taft LLP

FRB Governor Bowman Speaks on Financial Stability

Last week, Federal Reserve Board (“FRB”) Governor Michelle Bowman gave a speech entitled Financial Stability in Uncertain Times, focusing on the “financial stability risks and vulnerabilities” she is most focused on....more

Mayer Brown Free Writings + Perspectives

Cart Before Horse: Banking Regulators Extend Comment Period and Launch Data Collection for Basel Endgame

On October 20, 2023, the US federal banking regulators announced that they were extending the period for public comment to January 16, 2024 for both the (i) Basel Endgame proposal to significantly revise the risk-based...more

Troutman Pepper Locke

Federal Agencies Request Comment on Proposed Rule Requiring Large Banks to Maintain Long-Term Debt

Troutman Pepper Locke on

On August 29, the Board of Governors of the Federal Reserve System (Federal Reserve), Federal Deposit Insurance Corporation (FDIC), and Office of the Comptroller of the Currency (collectively, the agencies) issued a notice of...more

Venable LLP

Financial Regulatory Reform Tracker - Anti-Tailoring Efforts

Venable LLP on

Following the 2023 bank failures, the federal banking regulators (the Federal Reserve, the OCC, and the FDIC) have signaled that they are seeking to develop more stringent bank regulatory requirements for larger banking...more

Troutman Pepper Locke

Federal Agencies Issue Proposed Rulemaking Revising Capital Requirements for Large Banks

Troutman Pepper Locke on

On July 27, the Office of the Comptroller of the Currency, the Board of Governors of the Federal Reserve System, and the Federal Deposit Insurance Corporation (collectively, the agencies) issued a joint notice of proposed...more

Orrick, Herrington & Sutcliffe LLP

Fed vice chair calls for higher capital for large banks

On July 10, Federal Reserve Board Vice Chair for Supervision Michael S. Barr delivered remarks at the Bipartisan Policy Center outlining proposed updates to capital standards. As part of his holistic review of capital...more

Cadwalader, Wickersham & Taft LLP

Fed Vice Chair Barr Delivers Results of Holistic Capital Review

In a speech made at the Bipartisan Policy Center (“BPC”) on Monday, the Federal Reserve’s Vice Chair for Supervision, Michael S. Barr, communicated preliminary recommendations stemming from the holistic review of capital...more

Cadwalader, Wickersham & Taft LLP

Vice Chair Barr Speaks on Capital Levels

On December 1, Federal Reserve Board (“FRB”) Vice Chair of Supervision Michael Barr gave a speech at the American Enterprise Institute on Bank Capital. Vice Chair Barr noted that the FRB’s holistic review of capital standards...more

Cadwalader, Wickersham & Taft LLP

Federal Reserve Releases Large Bank Capital Requirements

Last week, the Federal Reserve Board (“FRB”) announced the individual capital requirements for all large banks, effective on October 1. This announcement follows the June announcement on the results of the supervisory stress...more

Goodwin

Financial Services Weekly Roundup: SEC Proposes Modified Disclosure Framework For Funds

Goodwin on

In the News. The Securities and Exchange Commission (SEC) proposed modifying the disclosure framework for mutual funds and exchange-traded funds (funds), which would create a new layered disclosure regime that attempts to...more

A&O Shearman

The Fed Repurposes the Financial Crisis Playbook for Pandemic Response

A&O Shearman on

In the face of the coronavirus (“COVID-19”) pandemic, the U.S. Federal Reserve Board (the “Fed”) and the U.S. federal banking agencies have announced several market and supervisory actions to address the sudden market stress...more

Skadden, Arps, Slate, Meagher & Flom LLP

Federal Banking Agencies Propose Updating Calculation of Derivative Contract Exposure Amounts

On October 30, 2018, the Board of Governors of the Federal Reserve System, the Federal Deposit Insurance Corporation, and the Office of the Comptroller of the Currency (collectively, the agencies) jointly invited comment on a...more

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