Several major revisions to the largest banks’ capital framework are underway or imminent, including proposed changes to leverage capital requirements, stress testing and the stress capital buffer, and risk-based capital requirements. States charter and supervise more than a dozen domestic and foreign banks with assets exceeding $100 billion, which account for roughly 40% of all state-chartered bank assets. CSBS has long maintained that the largest firms should be subject to clear, rational, and appropriately calibrated heightened standards that promote financial stability, a competitive banking system, and regulatory and supervisory transparency.