United States: Capital Adequacy/BASEL

When a bank pledges its own collateral to secure an affiliate's borrowing from a third-party lender, does this arrangement constitute a guarantee under Regulation W? The Federal Reserve's interpretation treats such pledges as covered transactions, with specific measurement rules that reflect the bank's actual exposure. Understanding how to properly classify and measure these arrangements is essential for compliance with quantitative limits.

The FDIC and Federal Reserve have issued proposed rules addressing state bank parity, merger procedures, and stablecoin regulation, while the Federal Reserve finalizes stress test changes to enhance transparency and reduce capital volatility. These regulatory developments reshape the landscape for interstate banking operations, merger transactions, and digital asset activities for financial institutions.

Federal banking regulators have proposed significant revisions to third-party risk management guidance, shifting from prescriptive requirements to a flexible, risk-based framework that gives banks greater discretion in managing vendor relationships. The proposal addresses longstanding concerns about the 2023 guidance being too rigid and includes a companion statement on community banks' relationships with core service providers.

Matt Bisanz and Tom Killian discuss innovative approaches to regulatory recognition of commercial real estate risk transfer in US banking. The conversation examines how banking agencies can enable responsible growth in commercial real estate lending while maintaining appropriate risk management standards.

Federal banking regulators have jointly proposed sweeping reforms to U.S. capital requirements, formally rescinding the controversial 2023 Basel III Endgame Framework in favor of a modernized approach that would reduce capital burdens...

The NAIC's Spring National Meeting addressed critical changes to risk-based capital factors for life insurers' collateral loans, with industry stakeholders debating the appropriate methodology for calculating RBC factors based on loan-to-value ratios and overcollateralization levels.

On April 23, 2026, the Office of the Comptroller of the Currency (OCC), Federal Reserve Board, and Federal Deposit Insurance Corporation (FDIC) jointly issued a final rule revising...

On March 19, 2026, the federal banking agencies issued a package of proposed changes to the regulatory capital requirements for banking institutions of all sizes, from the largest GSIBs and super-regional banks to community banks. This package of proposals (the “Proposed Rules”) is a second full attempt at implementing the 2017 “Basel III Endgame” international framework—following the agencies’ initial package of proposals in July 2023 (the “2023 NPR”)—to better reflect credit, trading and operational risk in the calculation of regulatory capital ratios.

On March 19, 2026, the federal banking agencies issued a package of proposed changes to the regulatory capital requirements for banking institutions of all sizes, from the largest GSIBs and super-regional banks to community banks. This package of proposals (the “Proposed Rules”) is a second full attempt at implementing the 2017 “Basel III Endgame” international framework—following the agencies’ initial package of proposals in July 2023 (the “2023 NPR”)—to better reflect credit, trading and operational risk in the calculation of regulatory capital ratios.