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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

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