Fed Updates Risk Formulas for Mega-Banks
Published Date: 3/27/2026
Proposed Rule
Summary
Big banks that matter most to the U.S. economy will see changes in how their risk-based capital surcharges are calculated. The new rules tweak formulas, smooth out data bumps, and update reports to better match real-world risks, with adjustments for growth and inflation each year. These updates aim to keep our financial system safer, and banks need to get ready by June 18, 2026, to share their thoughts.
Analyzed Economic Effects
9 provisions identified: 3 benefits, 1 costs, 5 mixed.
One-time Cut to Method 2 Coefficients
The rule would apply a one-time downward adjustment to the fixed Method 2 coefficients by a factor of 1.2 to reflect changes since implementation. The Board describes this 1.2 factor as equal to the observed 20-percentage-point divergence in cumulative growth between Method 2 and Method 1 scores since Q4 2019.
Annual Indexing of Coefficients to GDP
After the one-time adjustment, the Board would annually index Method 2 coefficients using a three-year moving average of nominal U.S. GDP growth. The Board would not adjust coefficients if the three-year moving average of nominal GDP growth is negative, and it expects to publish updated coefficients and the GDP growth scalar each year in the fourth quarter.
Short-Term Wholesale Funding Measure Changed
The proposal would modify the weighted short-term wholesale funding systemic indicator to measure an absolute amount rather than a ratio scaled to a firm's average risk-weighted assets, and set a new coefficient so the indicator represents approximately 20 percent of total Method 2 weighted basis points.
Average Reporting for Certain Indicators
For certain systemic indicators that are currently measured on a single year-end date, the proposal would require firms to calculate them as annual averages of daily or monthly values instead of point-in-time snapshots. This is intended to reduce the effects of temporary changes around measurement dates.
Narrower Method 2 Score Bands
The proposal would introduce narrower Method 2 score band ranges to reduce cliff effects and make GSIB surcharges more sensitive to changes in a firm's systemic risk profile.
Updates to Measurement and Definitions
The proposal would make multiple improvements to measurement of systemic indicators, including clarifications to the definition of 'financial institution' and the treatment of exchange-traded funds, updates to derivatives and securities outstanding measurement, trading volume and payments activity details (including currencies), and changes to cross-jurisdictional activity indicators.
FR Y-15 Reporting Clarifications and Streamlining
The proposal would amend the FR Y-15 Systemic Risk Report instructions and form to improve the consistency of data reporting and streamline the reporting process for respondents that file the FR Y-15 quarterly. The FR Y-15 applies to U.S. bank holding companies and covered savings and loan holding companies with $100 billion or more in consolidated assets and certain foreign banking organizations.
Clarification on In-Year Surcharge Reductions
The proposal includes a clarification regarding reduction in a GSIB surcharge calculated during the year between calculation and the effective date of a GSIB surcharge increase, as part of the amendments to the GSIB framework.
Foreign Banking Organization Reporting Changes
The proposal would include amendments related to reporting requirements for foreign banking organizations that have combined U.S. assets of $100 billion or more, as reflected in the FR Y-15 and related GSIB measurement changes.
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Key Dates
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