Large Bank Examination Workshop February 2026

2024 Developments • On September 10, 2024, Michael S. Barr, the Vice Chair for Supervision of the Federal Reserve, delivered a speech outlining a package of proposed revisions to the previous interagency proposal to revise the U.S. regulatory capital framework and the Federal Reserve’s proposed revisions to the capital surcharge applicable to U.S. SIFIs. • In contrast to the average 16 percent increase in common equity tier 1 capital requirements (including minimums and buffers) the agencies estimated would result from the original proposals, Vice Chair Barr indicated that the re proposals would increase aggregate common equity tier 1 capital requirements for the G-SIBs, which are the largest and most complex banks, by 9 percent. 57

2024 Developments • For large banks that are not G-SIBs, the impact from the re-proposal would mainly result from the inclusion of unrealized gains and losses on their securities in regulatory capital, estimated to be equivalent to a 3 to 4 percent increase in capital requirements over the long run. • This would increase capital requirements for non-G-SIB firms still subject to the rule by 0.5%. • Banks with assets between $100 and $250 billion would no longer be subject to the endgame changes, other than the requirement to recognize unrealized gains and losses of their securities in regulatory capital. 58

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