Title page
Contents
Summary 2
Introduction 5
Legislative History 6
The Dodd-Frank Act 6
P.L. 115-174 8
The 2019 EPR Rules Implementing P.L. 115-174 9
What Requirements Must Large Banks Comply with Under Enhanced Regulation? 11
Stress Tests, Capital Planning, and the Stress Capital Buffer 14
Resolution Plans ("Living Wills") 18
Liquidity Requirements 20
Single Counterparty Exposure Limits 21
Risk Management Requirements 22
Provisions Triggered in Response to Financial Stability Concerns 22
Basel III Capital Requirements 23
Advanced Approaches 24
Supplementary Leverage Ratio 24
G-SIB Capital Surcharges 25
Countercyclical Capital Buffer (CCYB) 26
Total Loss Absorbing Capacity 26
Supervision 27
Assessments 27
Role of EPR in 2023 Bank Failures 28
Proposed Changes to Large Bank Regulation 32
Incorporating the G-SIB Surcharge into the eSLR and TLAC 33
Holistic Capital Review 34
Basel III Endgame 35
Extending Coverage of SLR and CCYB 36
AOCI and Unrealized Capital Losses 36
G-SIB Surcharge Proposal 39
Long-Term Debt Proposal 39
FDIC's Resolution Proposal 41
Conclusion 42
Author Information 43
Acknowledgments 43
Disclaimer 43
Table 1. Current EPR Requirements for Banks 12
Table 2. Estimated Impact of Proposed AOCI Inclusion on Capital 37
Figure 1. Banks Subject to EPR 11
Figure 2. Risk-Weighted Capital Requirements for Large Banks, 2023 18
Figure 3. SLR Requirement for G-SIBs, Current and Under Proposed Rule 33
Figure 4. Unrealized Gains and Losses on Securities Held by FDIC-Insured Depository Institutions 38