News & Analysis as of

Capital Requirements Banks

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

Mayer Brown

CRD6: Implications for US Fund Finance Lenders

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The European Union’s new Capital Requirements Directive 6 (CRD6) introduces significant regulatory changes for non-EU banks operating within EU Member States. This update explores the impact of CRD6 on US lenders providing...more

Cadwalader, Wickersham & Taft LLP

CRD VI and Its Impact on Lending into Europe

December 2023 saw the publication by the EU of the near-final version of its ‘Banking Package’ that makes significant changes to the Capital Requirements Directive known as ‘CRD VI’. This article is going to focus on the CRD...more

Mayer Brown

UK Government consults on new rules to recapitalise small banks in resolution – What does this mean for potential buyers of...

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What is the government proposing? The UK government (“HM Treasury”) has launched a Consultation setting out its proposals to amend the UK special resolution regime (“SRR”) to direct that the UK depositor guarantee scheme...more

Ballard Spahr LLP

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

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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

Mayer Brown Free Writings + Perspectives

Basel Endgame Resource Center

The US federal banking regulators recently proposed extensive revisions to the regulatory capital requirements, referred to as the Basel Endgame.  The July and August proposals – targeted at banks with $100 billion (or more)...more

Cadwalader, Wickersham & Taft LLP

Industry Trades Really Don’t Like the Basel III Endgame Proposal

As we covered previously, on July 27, 2023, the U.S. prudential bank regulators (the Federal Deposit Insurance Corporation (“FDIC”), the Federal Reserve Board (“FRB”) and the Office of the Comptroller of the Currency (“OCC”)...more

Mayer Brown Free Writings + Perspectives

The Final Stretch: Securitization in the US Under the Proposed Basel III Endgame Rules

On July 27, 2023, the US banking regulators issued a notice of proposed rulemaking (the “NPR”) to revise significantly the risk-based capital requirements applicable to large banks and to banks with significant trading...more

Cadwalader, Wickersham & Taft LLP

The Three Federal Banking Agencies Propose Long-Term Debt Requirement for All Large Banking Organizations

The Federal Deposit Insurance Corporation (“FDIC”), Federal Reserve Board (“FRB”) and Office of the Comptroller of the Currency (“OCC”) (together, the “Agencies”) issued a proposed rule (the “LTD NPR”) to require large banks...more

Troutman Pepper

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

Troutman Pepper 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

What the Proposed Capital Rule Means for Smaller Banks and Other Non-Bank Participants in the Financial Services Market

Venable LLP on

Larger banking organizations directly affected by the U.S. federal banking agencies' recent proposed capital rule have been busy analyzing the substantial changes, increased costs, and other requirements and effects that have...more

Venable LLP

Financial Regulatory Reform Tracker - Anti-Tailoring Efforts

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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

Mayer Brown Free Writings + Perspectives

A Road Not Taken: Where the US Capital Proposal Differs From Basel

On July 27, 2023, US federal banking regulators issued proposals to (i) significantly revise the riskbased regulatory capital requirements for certain midsize and larger US banking organizations (the “Capital Proposal”) and...more

Jones Day

Federal Banking Agencies Propose Increased Capital Requirements for Large Banks

Jones Day on

In Short - The Situation: The federal banking agencies approved a proposal that would implement a "gold-plated" U.S. version of the "Basel III endgame."...more

Mayer Brown Free Writings + Perspectives

Overhaul of Regulatory Capital Requirements Proposed by US Banking Regulators

On July 27, 2023, US federal banking regulators issued proposals to (i) significantly revise the riskbased regulatory capital requirements for certain midsize and larger US banking organizations (the “Capital Proposal”), and...more

Vedder Price

Federal Regulators Issue Notice of Proposed Rulemaking Revising Capital Requirements for Large Banks and Banks with Significant...

Vedder Price on

On July 27, 2023, in an effort to bolster the resilience of the U.S. banking system in the aftermath of recent bank failures and to promote consistency with international banking capital standards, the Federal Deposit...more

Troutman Pepper

Federal Agencies Issue Proposed Rulemaking Revising Capital Requirements for Large Banks

Troutman Pepper 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

Agencies propose new capital requirements for biggest banks

On July 27, the FDIC’s Board of Directors unveiled proposed interagency amendments to the regulatory capital requirements for the largest and most complex banks in the United States. The notice of proposed rulemaking (NPRM),...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

Troutman Pepper

Connecticut Banking Statutes Amendments Take Effect October 1

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On June 29, Connecticut Governor Ned Lamont signed SB 1033, An Act Concerning Various Revisions to the Banking Statutes, into law. As discussed here, with this bill, Connecticut joins several other states that have set strict...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

The UK’s Model Risk Management Principles for Banks

Against a background of increasing reliance on models and scenario analysis to assess future risks, the UK’s bank regulator, the Prudential Regulation Authority (“PRA”), has published a supervisory statement on “Model risk...more

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