On July 27, 2023, the US banking regulators issued a proposal to significantly revise the risk-based capital requirements applicable to large banks and to banks with significant trading activity. The proposal, which is colloquially referred to as “Basel III Endgame” or “Basel IV,” includes important changes to the calculation of credit risk weights for securitization
Matthew Bisanz
Global Financial Markets Podcast Series: How Capital Markets May Be Affected by the US Basel Endgame Proposal
In late July 2023, US banking agencies released proposals to significantly revise the risk-based regulatory capital requirements for certain midsize and larger US banking organizations, and change how the capital surcharge is calculated for global, systemically important banking organizations. These proposals are critical, as the amount of capital a bank must maintain with respect to…
Long-Term Debt Requirements Proposed for US Regional Banks
On August 29, 2023, US federal banking regulators issued a proposal for long-term debt (“LTD”) requirements on certain midsize and larger US banking organizations (the “LTD Proposal”). The LTD Proposal is important because it would require many regional and larger banking organizations to issue significant amounts of LTD. In this Legal Update, we provide background…
MB Microtalk: BCBS Core Principles

In this MB Microtalk video, Mayer Brown’s Matt Bisanz discusses a recent proposal from the Basel Committee on Banking Supervision regarding revisions to the Core Principles for Effective Banking Supervision. These changes to the Core Principles come on the heels of the recent disruptions in the banking sector.
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A Road Not Taken: Where the US Capital Proposal Differs From Basel
On July 27, 2023, US federal banking regulators issued proposals to significantly revise the risk-based regulatory capital requirements for certain midsize and larger US banking organizations (the “Capital Proposal”) and change the method for calculating the capital surcharge for global systemically important banking organizations (“G-SIBs”). These proposals are of critical importance because the amount of…
Overhaul of Regulatory Capital Requirements Proposed by US Banking Regulators
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 globally systemically important banking organizations (“G-SIBs”) (the “G-SIB Surcharge Proposal”). These proposals are of…
Basel Committee Seeks Public Comments on Bank Supervision
Banking organizations should take note that last week the Basel Committee on Banking Supervision (“Basel Committee”) released proposed revisions to its core principles for effective banking supervision (the “Revised Principles”). The Revised Principles, if adopted by the Basel Committee, will not have the force of law on their own. However, the International Monetary Fund and…
Maintaining Perspective: Governance and Disclosure Reminders for Public Companies
Companies will be affected in a variety of ways by the receivership of Signature Bank, Silicon Valley Bank or any other similarly situated financial institution. Companies may face difficulty accessing bank facilities or the capital markets or limitations on money market or commercial paper facilities. Resulting liquidity constraints may entail difficult decisions, including prioritizing the…
Virtual Currency Activity Prior Approval Requirement Established by NYDFS
On December 15, 2022, the New York Department of Financial Services (“NYDFS”) issued guidance clarifying that all New York banking organizations are required to obtain prior agency approval for virtual currency-related activity (“2022 Guidance”). The 2022 Guidance is similar to prior notice guidance issued by the federal banking regulators but establishes highly prescriptive information requirements…
SEC Proposes Climate Change Disclosure Rules Applicable to Public Companies
On March 21, 2022, the US Securities and Exchange Commission (SEC) voted 3:1, with only Commissioner Hester Peirce dissenting, to propose long-awaited rules that, if adopted, would require extensive reporting by public companies of climate change-related disclosure and related attestation (the “Proposal”). Comments on the Proposal are due 30 days after publication in the Federal…