OFR_2016_Financial-Stability-Report
OFR_2016_Financial-Stability-Report
OFR_2016_Financial-Stability-Report
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The Federal Reserve’s CCAR<br />
has forced several G-SIBs to revise<br />
their capital plans. Some of these<br />
banks had reported regulatory capital<br />
ratios well above required minimums.<br />
CCAR has resulted in those<br />
banks holding additional capital. In<br />
the <strong>2016</strong> CCAR severely adverse<br />
scenario, seven of the eight U.S.<br />
G-SIBs were closer to a breach of<br />
the leverage ratio than they were<br />
to a breach of any of the regulatory<br />
minimums for risk-based capital<br />
standards. The more stringent supplementary<br />
leverage ratio is now<br />
being phased in. CCAR does not yet<br />
measure banks’ ability to meet this<br />
new standard. Potential changes in<br />
banks’ business models bear monitoring,<br />
because the <strong>2016</strong> CCAR<br />
results suggest that U.S. G-SIBs<br />
are more constrained by leverage<br />
standards than risk-based capital<br />
standards (see Figure 67). Possible<br />
inclusion in CCAR minimums of<br />
additional risk-based capital buffers, including the G-SIB buffer, which are<br />
also phasing in now, could also affect large bank behavior.<br />
Figure 67. Binding Ratios Under the Comprehensive Capital Analysis<br />
and Review<br />
Large banks in the United States are more constrained by the leverage ratio<br />
than by risk-based capital ratios<br />
Bank 2013 2014 2015 <strong>2016</strong><br />
Bank of America<br />
Bank of New York Mellon<br />
Citigroup<br />
Goldman Sachs<br />
JPMorgan Chase<br />
Morgan Stanley<br />
State Street<br />
Wells Fargo<br />
Risk-based capital ratio<br />
Leverage ratio<br />
Binding ratio Breach of ratio<br />
Note: Breach of ratio indicates the bank’s regulatory ratio fell below regulatory requirements<br />
during the stressed period. If there was no breach of the bank’s regulatory ratio,<br />
the ratio that came closest to a breach is indicated as the binding ratio.<br />
Sources: Federal Reserve Board of Governors, <strong>OFR</strong> analysis<br />
Conclusion: Macroprudential Supervision and Resolution<br />
Planning Need Attention<br />
Supervisory monitoring and stress testing need to adapt to increasing noncommercial-banking<br />
activities at some U.S. G-SIBs. Supervisors need to<br />
monitor whether recent regulatory changes affect banks’ behavior in unanticipated<br />
ways or make U.S. G-SIBs more uniform over time. Banks may<br />
look safe from a microprudential perspective, but the system as a whole may<br />
be more vulnerable to common shocks. This problem argues for a macroprudential<br />
approach to monitoring these banks.<br />
Living wills for G-SIBs have not met supervisors’ standards. Data gaps<br />
in the public portions of living wills may increase uncertainty about what<br />
would happen if a U.S. G-SIB were to fail. These data gaps also raise questions<br />
about whether exceptional government support for large U.S. banks<br />
might occur again in the future.<br />
Key Threats to <strong>Financial</strong> <strong>Stability</strong> 75