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Large Bank Capital Requirements
Position Summary
Several major revisions to the largest banks’ capital framework are underway or imminent, including 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.

Large Bank Capital Requirements News

Comment Letter
Download the Full Comment Letter [PDF] Ann E. Misback, Secretary Federal Reserve Board of Governors 20th Street and Constitution Avenue NW Washington, DC 20551 Docket No. R-1867; RIN 7100-AG96 Jennifer M. Jones, Deputy Executive Secretary Federal Deposit Insurance Corporation 550 17th Street NW Washington, DC 20429 RIN 3064-AG11 Chief Counsel's Office Attention: Comment Processing Office of the Comptroller of Currency
August 26, 2025
Comment Letter
Download the Comment Letter [PDF] Consumer Financial Protection Bureau 1700 G Street NW Washington, DC 20552 Comment Intake – 2024 NPRM Overdraft c/o Legal Division Docket Manager Docket No. CFPB-2024-0002 RIN 3170-AA42 Re: Proposed Rule – Overdraft Lending: Very Large Financial Institutions Dear Sir or Madam: The Conference of State Bank Supervisors 1 (“CSBS”) provides the following comments on the
April 1, 2024
Comment Letter
Download the Comment Letter [PDF] James P. Sheesley, Assistant Executive Secretary Attention: Comments/Legal OES Federal Deposit Insurance Corporation 550 17th Street NW Washington, DC 20429 RIN 3064-AF94 Re: Guidelines Establishing Standards for Corporate Governance and Risk Management for Covered Institutions with Total Consolidated Assets of $10 Billion or More Dear Sir or Madam, The Conference of State Bank Supervisors (“CSBS”)
February 7, 2024
Comment Letter
Download the Full Letter [PDF] Office of the Comptroller of the Currency 00 7th Street SW, Suite 3E-218 Washington, DC 20219 Chief Counsel’s Office Attention: Comment Processing Docket ID OCC-2023-0011 Board of Governors of the Federal Reserve System 20th Street and Constitution Avenue NW ashington, DC 20551 Ann E. Misback, Secretary Docket No. R-1815 RIN 7100-AG66 Federal Deposit Insurance Corporation
January 17, 2024
Comment Letter
Download the Full Letter [PDF] Office of the Comptroller of the Currency 400 7th Street SW, Suite 3E-218 Washington, DC 20219 Chief Counsel's Office Attention: Comment Processing Docket ID OCC-2023-0011 Board of Governors of the Federal Reserve System 20th Street and Constitution Ave NW Washington, DC 20551 Ann E. Misback, Secretary Docket No. R-1815 RIN 7100-AG66 Federal Deposit Insurance Corporation
January 16, 2024
Comment Letter
Download the Full Letter [PDF] Office of the Comptroller of the Currency 400 7th Street SW, Suite 3E-218 Washington, DC 20219 Chief Counsel's Office Attention: Comment Processing Docket ID OCC-2023-0011 Board of Governors of the Federal Reserve System 20th Street and Constitution Ave NW Washington, DC 20551 Ann E. Misback, Secretary Docket No. R-1815 RIN 7100-AG66 Federal Deposit Insurance Corporation
January 16, 2024
Comment Letter
In light of the significant implications for financial stability and the resiliency of the U.S. banking industry, state bank regulators believe it is important that agreement across all of the federal banking agencies should be reached before any proposed revisions to the eSLR are issued or adopted.
June 25, 2018