On July 27, 2023, US federal banking regulators issued proposals to (i) significantly revise the risk-based regulatory capital requirements for certain midsize and larger US banking organizations (the “Capital Proposal”) and (ii) change the method for calculating the capital surcharge for global systemically important banking organizations (“G-SIBs”) (the “G-SIB Surcharge Proposal”). 1 As we discuss in our earlier, comprehensive Legal Update , these proposals are of critical importance because the amount of capital a bank must maintain with respect to any particular loan, investment or activity is typically a significant—if not the most significant—factor in determining whether the relationship […]
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