Resources and guidance relating to the overhaul of regulatory capital requirements proposed by US banking regulators.
Below, we include links to Mayer Brown’s Legal Updates, seminars and podcasts, and other useful materials to help you navigate these proposals.
In late July 2023, US banking regulators 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, colloquially referred to as “Basel III Endgame,” are critical, as the amount of capital a bank must maintain with respect to any particular loan, investment or activity is typically a significant factor in determining whether the relationship is profitable or even feasible.
Following industry comment, a quantitative impact study, and the passage of time, the banking agencies reproposed the rules for comment in March 2026.
BASEL ENDGAME RE-PROPOSAL 2026
Quick Links
- US Banking Regulators Propose Reforms to Capital Requirements (March 20, 2026)
Mayer Brown Legal Update
The 2026 Re-Proposal
On March 19, 2026, US federal banking regulators, including the Board of Governors of the Federal Reserve System (“Federal Reserve”), the Office of the Comptroller of the Currency (“OCC”), and the Federal Deposit Insurance Corporation (“FDIC”) issued proposals to: (i) significantly revise the risk-based regulatory capital requirements for Category I and II banking organizations; (ii) change the risk weights that other banking organizations apply to credit exposures; and (iii) change the method for calculating the capital surcharge for globally systemically important banking organizations (“G-SIBs”).
Read the Federal Reserve Board Memo:
Read the Proposed Rules:
- Regulatory Capital Rule: Risk-Based Capital Surcharges for Global Systemically Important Bank Holding Companies; Systemic Risk Report
- Regulatory Capital Rule: Category I and II Banking Organizations, Banking Organizations with Significant Trading Activity, and Optional Adoption for Other Banking Organizations
- Regulatory Capital Rules: Regulatory Capital and Standardized Approach for Risk-weighted Assets
The boards of the Federal Reserve and FDIC met simultaneously to vote on proposed new capital rules for small and large banks, including a re-proposal of the Basel Endgame capital plan.
- Read the FDIC’s meeting notice
- Read the Federal Reserve’s meeting notice
Speeches & Commentary on 2026 Re-Proposal
- Statements on Bank Capital Proposals by Chair Jerome H. Powell (March 19, 2026)
- Statements on Bank Capital Proposals by Vice Chair for Supervision Michelle W. Bowman (March 19, 2026)
- Statement by Chairman Travis Hill on Risk-Based Capital Proposals (March 19, 2026)
- Comptroller Gould Statement on Notice of Proposed Rulemakings to Modernize Regulatory Capital Framework (March 19, 2026)
- Capital Rules for the Real Economy (March 12, 2026)
Speech by Vice Chair for Supervision Michelle W. Bowman
Cato Institute Policy Forum: Basel III and Bank Capital Rules - An Update on Reforms to the Regulatory Toolkit (March 11, 2026)
Remarks by FDIC Chairman Travis Hill
American Bankers Association Washington Summit - Liquidity Resiliency, Financial Stability, and the Role of the Federal Reserve (March 3, 2026)
Vice Chair for Supervision Michelle W. Bowman
The Roundtable on Liquidity and Lender of Last Resort sponsored by the Committee on Capital Markets Regulation
BASEL ENDGAME PROPOSAL 2023-2024
Quick Links
- Overhaul of Regulatory Capital Requirements Proposed by US Banking Regulators
(Mayer Brown Legal Update) - Overhaul of Regulatory Capital Requirements Proposed By US Banking Regulators, Part 1 (Mayer Brown Global Financial Markets Podcast)
- Joint Trade Association’s Letter Regarding Proposals
Request for Re-Proposal of Regulatory Capital Rule to Remedy Administrative Procedure Act Violations
JUMP TO 2026 RE-PROPOSAL
Comment Letters on 2023-2024 Proposal
Mayer Brown has been actively engaged on this important rulemaking and have helped clients draft numerous comment letters including:
- The Structured Finance Association
- The National Association of Manufacturers
- The London Stock Exchange Group
- The CRE Finance Council
Publications on 2023-2024 Proposal
- Basel Endgame rewrite to ease capital, securitization impact limited
Structured Credit Investor, February 25, 2026 - Out With a Whimper: BCBS Publishes Climate Disclosure Framework
Mayer Brown Legal Update, June 20, 2025 - Outline CRR III / CRD VI – Final Basel III Standards
Mayer Brown Legal Update, June 21, 2024 - Regulators Preparing to Finalize Basel IV
Mayer Brown Legal Update, May 14, 2024 - Time Warp? Proposed Basel Endgame Reporting Requirements Released Before Final Rule
Mayer Brown Legal Update, January 29, 2024 - Mayer Brown Discusses Proposed Long-Term Debt Requirements for U.S. Regional Banks
The Columbia Law School Blue Sky Blog, September 8, 2023 - Long-Term Debt Requirements Proposed for US Regional Banks
Mayer Brown Legal Update, August 31, 2023 - The Final Stretch: Securitization in the US Under the Proposed Basel III Endgame Rules
Mayer Brown White Paper, August 31, 2023 - Mayer Brown Discusses Bank Regulators Proposed Overhaul of Capital Requirements
The CLS Blue Sky Blog, August 10, 2023 - A Road Not Taken: Where the US Capital Proposal Differs From Basel
Mayer Brown Legal Update, August 10, 2023 - Overhaul of Regulatory Capital Requirements Proposed by US Banking Regulators
Mayer Brown Legal Update, July 31, 2023 - Basel Endgame Intentions Announced by US Banking Regulators
Mayer Brown Legal Update, September 12, 2022
Podcasts on 2023-2024 Proposal
- Fed Chair Powell’s Update on Basel Endgame
Mayer Brown Financial Services Focus Podcast, July 11, 2024 - Operational Risk Considerations Under the US Basel Endgame Proposal
Mayer Brown Global Financial Markets Podcast, November 21, 2023 - How Mortgage Markets May Be Affected by the US Basel Endgame Proposal
Mayer Brown Global Financial Markets Podcast, November 9, 2023 - How Commercial Real Estate Lending May Be Affected by the US Basel Endgame Proposal
Mayer Brown Global Financial Markets Podcast, October 23, 2023 - Market Risk Considerations Under the US Basel Endgame Proposal
Mayer Brown Global Financial Markets Podcast, October 30, 2023 - Long-Term Debt Requirements Proposed for US Regional Banks
Mayer Brown Global Financial Markets Podcast, September 20, 2023 - What US Basel Endgame Means Outside of the United States
Mayer Brown Forum: A Law Firm Community Podcast, September 18, 2023 - How Securitization and Structured Finance May Be Affected by the US Base; Endgame Proposal, Part 3
Mayer Brown Global Financial Markets Podcast, September 13, 2023 - How Capital Markets May Be Affected by the US Basel Endgame Proposal
Mayer Brown Global Financial Markets Podcast, August 31, 2023 - MB Microtalk: BCBS Core Principles
Mayer Brown Microtalk, August 17, 2023 - Overhaul of Regulatory Capital Requirements Proposed By US Banking Regulators, Part 1
Mayer Brown Global Financial Markets Podcast, August 3, 2023
House Hearing on 2023-2024 Proposal
On September 14, 2023, Mayer Brown partner Andrew Olmem testified before the House Financial Services Committee at a hearing titled “Implementing Basel III: What’s the Fed’s Endgame?”
Events & Presentations on 2023-2024 Proposal
- What to Expect in Banking Regulation in 2026
PLI Webinar, January 21, 2026 - The FDIC’s Governance Proposal
Mayer Brown Webinar, March 15, 2024 - Basel III Endgame’s Impact on Real Estate Finance
Strafford, January 17, 2024 - Basel III Endgame – What Does It Mean For Banks And The Mortgage Industry
Women in Housing and Finance, December 14, 2024 - Proposed Overhaul of Bank Regulatory Capital Requirements
DC Bar, October 11, 2023 - What the Basel Endgame Proposal Means for Arizona Banking Institutions
Arizona Bankers Association, October 5, 2023 - Basel Endgame Conference
New York State Bar Association, October 4, 2023- Impact of Basel Endgame and Long-Term Debt Proposals on the US Banking System (9:00 am – 10:00 am ET)
- Access the panel presentations and webinar replay
- Keynote Address by the Director of the FDIC Board of Directors, Jonathan McKernan (10:00 am – 10:45 am ET)
- How Banks May Respond to the Basel Endgame and Long-Term Debt Proposal (11:00 am – 12:00 pm ET)
- Access the panel presentations and webinar replay
- Impact of Basel Endgame and Long-Term Debt Proposals on the US Banking System (9:00 am – 10:00 am ET)
- An Overview of Regulatory Capital Requirements Proposed Revisions
Mortgage Bankers Association, September 27, 2023 - Basel Endgame for Small and Medium International Banks
International Investment Bank’s Small and Medium Bank Group, September 21, 2023 - Recent Changes in Banking Regulation
Fordham Corporate Law Center Webinar, September 19, 2023 - The Basel Endgame and its Effect on the Mortgage Market, Mortgage REITs, and Access to Capital, 2023 Mortgage & Housing Summit
Mortgage Bankers Association & Mayer Brown, September 18, 2023 - Proposed Bank Capital Requirements: Basel III Endgame Implementation
Strafford Webinar, September 14, 2023 - New Capital Requirements and Basel Endgame: What Practitioners Need to Know
American Law Institute, September 13, 2023 - Proposed Overhaul of Bank Regulatory Capital Requirements
CRE Finance Counsel Webinar, September 12, 2023 - Basel Endgame: It’s Just the Beginning for New U.S. Bank Capital Requirements
PLI Webinar, September 12, 2023 - What the Basel Endgame Proposal Means for Delaware Banking Institutions
Delaware Bankers Association, September 12, 2023 - What the Basel Endgame Proposal Means for US Financial Services
New York City Bar Association Webinar, September 7, 2023 - Overhaul of Regulatory Capital Requirements Proposed By US Banking Regulators
National Academy of Continuing Legal Education Webinar, August 17, 2023 - The Impacts of the Fed’s New Bank Capital Standards
Raymond James Webinar, August 1, 2023