Bank Capital Requirements

• Earlier today, following a June 25, 2025 Federal Reserve Board open meeting, the Federal Reserve, the FDIC and the OCC issued a joint proposal to modify the enhanced supplementary leverage ratio requirements (“eSLR”) for U.S. top-tier bank holding companies that are identified as U.S. global systemically important BHCs (“GSIBs”) and their subsidiary depository institutions. The proposal also would modify the Federal Reserve’s total loss-absorbing capacity (“TLAC”) leverage buffer and leverage-based long-term debt (“LTD”) requirements for U.S. GSIBs.
• The structure of the eSLR, TLAC leverage buffer and leverage-based LTD requirements in the proposal broadly aligns with the structure in a joint proposal that the Federal Reserve and the OCC issued in April 2018, with two important modifications.
• Comments on the proposal are due on August 26, 2025.

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