News & Analysis as of

Federal Reserve Capital Requirements

Davis Wright Tremaine LLP

Federal Reserve Board Proposes Revisions to Large Financial Institution Rating System

On July 15, 2025, the Federal Reserve Board released a proposed rule to revise the Large Financial Institution rating system or "LFI Framework." The proposal would change how the Fed evaluates the financial and managerial...more

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

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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

Prudential regulators propose rule on bank capital requirements

On June 27, the OCC, the Fed, and the FDIC issued a notice of proposed rulemaking to revise the enhanced supplementary leverage ratio standards for U.S. global systemically important banks (GSIBs) and their subsidiaries. The...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

Loeb & Loeb LLP

Banking Agencies Propose Long-Sought Changes to Capital Rules for the Largest U.S. Banks

Loeb & Loeb LLP on

The Federal Reserve, alongside the Office of the Comptroller of the Currency (OCC) and Federal Deposit Insurance Corporation (FDIC), released their highly anticipated Notice of Proposed Rulemaking to overhaul the Enhanced...more

Mayer Brown Free Writings + Perspectives

US Banking Regulators Propose Enhanced Supplementary Leverage Ratio Reform

Last week, the US federal banking regulators proposed changes to the enhanced supplementary leverage ratio (“eSLR”) requirement for US global systemically important bank holding companies (“US GSIBs”) (the “Proposal”)....more

Cadwalader, Wickersham & Taft LLP

The Fine Print, June 2026 - Federal Banking Agencies Issue Proposed Rulemaking To Amend eSLR

This week, the Federal Reserve Board (“FRB") and the Office of the Comptroller of the Currency (“OCC”) issued a notice of proposed rulemaking (“NPR") to amend the Enhanced Supplementary Leverage Ratio (“eSLR”). At the time of...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

Orrick, Herrington & Sutcliffe LLP

Fed’s Bowman emphasizes a cautious monetary policy and regulatory reform for community banks

On February 17, Fed Governor Michelle Bowman delivered prepared remarks, during a conference in Arizona, addressing monetary policy, the economic outlook, and regulatory issues affecting community banks. She discussed the...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

Mayer Brown

How Regulation W Affects Subscription Credit Facilities

Mayer Brown on

EXECUTIVE SUMMARY - Section 23A of the Federal Reserve Act and its implementing regulation, Regulation W, impose restrictions on banks concerning “covered transactions” with their affiliates. With the increasing...more

Troutman Pepper Locke

Wall Street Notches Another Win as Fed’s Barr Clears the Way for Gentler Banking Regulator

Troutman Pepper Locke on

Alex Barrage, a partner with Troutman Pepper Locke, was quoted in the January 7, 2025 CNBC article, “Wall Street Notches Another Win as Fed’s Barr Clears the Way for Gentler Banking Regulator.”...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

ArentFox Schiff

Avoiding Collateral Damage: Lessons of Lehman [Part II]

ArentFox Schiff on

In light of the banking failures of Silicon Valley Bank, Signature Bank and First Republic (as well as Credit Suisse), this summer, the Federal Reserve and the FDIC proposed guidance and rules for larger banks to (i) develop...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

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