The changes that matter for bank capital strategy in the US Basel III Endgame Reproposal

KEY TAKEAWAYS

• Implementation is moving fast: With only a 3-month comment period, regulators are signaling a potential 2027 rollout, faster than typical timelines for rules of this size.
• Fewer banks in scope: The threshold for the strictest market risk rules increased from $1B to $5B in trading assets, reducing the number of banks subject to the most complex requirements.
• Strategic flexibility is increasing: Banks may lower capital using expanded risk-based models, while changes (like easier ETF treatment) could reduce costs and expand hedging options across the industry.

Following our recent overview of the revised Basel III Endgame proposal, this blog focuses on the elements with the most practical impact, and the strategic decisions that banks of all sizes will need to make.

The Basel III Endgame reproposal issued by the primary United States banking regulators (Federal Reserve, FDIC, OCC) on March 19th contains about 340,000 words, about as many as The Brothers Karamazov.

Going by the typical length of audiobook versions of Dostoyevsky’s classic, the reproposal would likely take 35-40 hours to read out loud. While one might wonder what else could be left to say on the subject, a short guide to which aspects of the reproposal have the most practical impact, from both strategic and operational standpoints, may still be in order.

Fast-tracked timeline and global alignment

To begin with, after consistently preparing the financial industry for a Q1 reproposal since last summer, the agencies delivered one – on schedule. In light of the fate of the prior revision (expected in late 2024 but shelved when it lost support among US regulators), this was by no means a foregone conclusion. A related point is that the reproposal leaves only three months for comments (six is probably both more common for a proposal of this magnitude and closer to industry expectation). This lays the groundwork for a rapid implementation schedule: cutting off comments by June makes it realistic to finalize the rules before the end of the year, making 2027 implementation a possibility. While there are many moving parts, and no issued schedule beyond the comment period, “just get it done,” without delay, is likely the regulators’ intent.

If so, this also signals an intent to stay roughly aligned with the global timeline. In recent years, global Basel III timing dynamics, particularly between the US and Europe, have resembled a baseline rally in tennis in which each player hits to the other’s backhand (the slower side). That is, each side of the Atlantic (the net) has pushed its implementation schedule back enough so the other side could match their pace, but with enough leeway to leave room for further delays. The EU and UK’s recent commitment to 2027 FRTB implementation, closing off further delays while still giving the US room to catch up, is then a redirection to the faster forehand side. We can view the reproposal as the US hitting the ball back, signaling that it intends to keep pace.

Where U.S. rules differ and why it matters

The next aspect is that, for all the talk of cross-jurisdiction divergence, the US version fits squarely into the global Basel III framework in content, not just timing. The primary industry objections to the last published version (double counting aspects of market risk between FRTB and the GSIB surcharge and an overly punitive treatment of bank mortgage lending) have been addressed within the US-specific parts of the framework, while leaving the Basel components intact, at least at a high level. Multinational banks will still need to take into account technical differences in form across jurisdictions, but it appears that regulators want to keep capital levels roughly aligned globally.

That said, there are still several US-specific aspects of the reproposal worth highlighting, as they lead to strategic choices for banks of all sizes:

1. For the largest global banks, the reproposal makes the Internal Models Approach (IMA) more attractive for market risk capital (FRTB). Steps in this direction include relaxation of risk factor eligibility and P&L attribution test requirements, as well as removing the output floor, which would have forced banks to calculate Standardized Approach (SA) capital even for IMA desks. Only a few banks globally, and certainly none but the very largest ones, have been willing to test the IMA waters so far, and it remains to be seen whether these steps change the dynamics.
   
2. For smaller institutions, the threshold for “significant trading activity,” which brings banks in scope for the Expanded Risk-Based Approach (including FRTB) has been raised from USD 1B to 5B in trading assets. This leaves a few banks which are currently in scope for the Market Risk Rule outside the new requirements. Such banks have two strategic choices to make: first, whether ERBA/FRTB could still help them lower capital, and, second, if less intensive risk calculations are required for regulatory capital, how to make sure that their internal risk management doesn’t suffer (and improves, ideally).
3. Many larger regionals and super-regionals use ETF exposures for hedging, and the operational burden of capitalizing those exposures in a way that captures the hedging benefit has been lightened in the reproposal. This includes thresholds for constituent information for full look-through and applicability of both index and mandate approaches. Banks that may have been considering reducing the use of funds to hedge because of capital cost under Basel III now have more strategic options at their disposal.

In addition, differences in the specific form of the US rules still matter operationally, even if they do not produce significant differences in capital. In particular, multinationals need the operational flexibility to calculate capital under multiple regimes. One US-specific feature, which is not new but still matters, is that use of external ratings to determine credit quality and thereby risk weights, is disallowed under Dodd-Frank. Other differences include risk buckets for credit spread and commodity risk classes, loss given default (LGD) assumptions for the Default Risk Charge, and inflation indexing for determining which equity issuers qualify as Large Market Cap.

Implementation challenges and benchmark essentials

The next 12-18 months of Basel III and FRTB implementation will likely generate operational as well as strategic challenges for both global and US-focused banks. Bloomberg stands ready to help, with Regulatory Data Solutions including data products specifically tailored to both FRTB Standard Approach and Internal Model Approach requirements (risk buckets and risk weights, fund holdings, time series and modellability) and FRTB SA sensitivity and capital calculations inside the Multi-Asset Risk System (MARS). MARS analytics are based on Bloomberg data as well as the cross-asset class, instrument-level pricing models that power the terminal. 

With the tight regulatory timeline, benchmarking FRTB calculations, both to ensure compliance and as an input to strategic decisions, becomes an internal imperative. It will likely also be a regulatory one: the initial Basel III Endgame proposal of 2023 was rapidly followed by a Hypothetical Portfolio Exercise (HPE) in which the regulators defined a set of benchmark portfolios and asked banks in scope for FRTB to submit capital calculations for them. This will likely be repeated later this year for banks currently in scope based on the new thresholds. 

Banks not in scope may still want to benchmark (using the regulatory portfolios or with the bank’s own) to gain insight into whether adopting FRTB could lead to a material reduction in their capital requirements. Operationally, both regulatory and internal benchmarking exercises need to be completed rapidly to be relevant. Having helped a number of banks through the 2023 HPE, Bloomberg stands ready to help banks as needed, with both data solutions and capital calculations.