Federal regulators are preparing to publish a revised set of bank capital proposals this week that would scale back earlier, more stringent requirements for major U.S. banks, according to officials briefed on the matter. The adjustments mark a notable retreat from the 2023 draft, which had called for double-digit increases in capital for some institutions.
Michelle Bowman, the Federal Reserve vice chair for supervision, said last week that big bank capital requirements will fall slightly under the upcoming proposal. The changes will affect how banks calculate the capital they hold to cover credit, market and operational risks, altering both the international Basel implementation and the surcharge applied to the largest global systemically important banks - the GSIB surcharge.
What the revision does
The new draft streamlines several provisions that drew intense industry opposition under the 2023 proposal. Among the provisions being removed is a requirement that banks meet the stricter of two methods for measuring risk-weighted assets, a measure that had been particularly punitive for large trading-focused banks. The revision also eases operational risk treatment for fee-based activities such as credit card portfolios, which would have faced tougher charges under the earlier text.
At the same time, regulators plan to recalibrate the GSIB surcharge by updating certain economic inputs and modifying how short-term funding risk is calculated. That change could lower surcharges for the most systemically important U.S. banks, including some of the largest global firms.
Industry reaction and internal debate
The shift toward less onerous requirements follows an extended campaign by large banks to blunt the 2023 draft, which several industry participants said would have forced material capital increases for some institutions. The original draft, introduced under Bowman's Democratic predecessor, had cited recent bank failures as justification for higher buffers, a move that prompted strong pushback from lenders who argued they were already well capitalized.
Industry sources and analysts note, however, that not all banks stand to benefit equally from the revisions. Some institutions may see larger reductions in capital needs, while others will have less to gain, a dynamic that could prompt further lobbying and internal sector negotiation once the full text is public. "Not all large banks are the same," said Brian Gardner, chief Washington policy strategist at Stifel, noting that reactions will depend on the specific business and balance sheet composition at each firm.
Analysts expect a lengthy and detailed review by banks once regulators publish the draft. Ian Katz, managing director at Capital Alpha Partners, emphasized the technical heft of the proposal: "You’re going to get several hundred pages, possibly a thousand pages of documents. There’s just going to be so much to go over, and some of it is highly technical."
Outstanding technical issues
Despite the easing of certain measures, several complex technical questions remain unresolved in the draft. Banks continue to seek clarity on the extent to which they may use internal models to assess market risk versus a standardized model imposed by regulators. Another sticking point is how much capital must be held against securities that are not publicly listed.
These and other granular modeling issues are central to how much capital individual institutions ultimately must hold. Industry officials caution that detailed rule text could still produce materially different outcomes across firms because of variations in business models and balance sheet structure.
Timing and procedural hurdles
The agencies expect to publish the draft soon, after which banks will have a 90-day comment window. Given the complexity of the proposals, regulators and market participants anticipate an extended period of scrutiny. Some analysts estimate that a final rule could remain more than a year away, with one research team suggesting it may not be finalized until early 2027.
Finalizing the rule requires coordinated action by multiple agencies. At the Federal Reserve, changes must be approved by its bipartisan board. Industry sources say Democratic board members could threaten to dissent if they judge the final rule to be too lenient. The forthcoming vote at the Fed will also occur in the context of a potential new Fed chair, as President Trump’s nominee to replace the current chair has not publicly taken a position on these capital changes.
Under a 2025 executive order, the completed rule will have to undergo review by the White House Budget Office, creating an additional procedural step that could affect the timeline. Still, some observers noted that regulators and banks appear generally aligned on the need for adjustment, which could make it "much easier" for agencies to reach agreement than it was during the earlier, more contentious drafting stage, according to University of Michigan professor Jeremy Kress.
Implications for the banking sector
If adopted in the form previewed by regulators, the revisions would lower some capital requirements that large banks had feared, easing projected increases first flagged in mid-2023. That could reduce near-term capital pressures for big U.S. banks, though differences in how the final text treats various business lines and models mean results will vary by firm.
Spokespeople for the Fed, the Federal Deposit Insurance Corporation and the Office of the Comptroller of the Currency either declined to comment or did not respond to requests for comment. Bank spokespeople also either declined to comment or did not immediately respond to requests.
Bottom line
The forthcoming drafts represent a clear change in direction from regulators compared with last year’s more aggressive approach. However, technical complexity, potential political dissent and mandatory interagency and White House reviews suggest the path to a final, implemented rule will be protracted and may still produce significant differences in outcomes across the largest banks.