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CONTACT:&nbsp;Barbara Hagenbaugh(202) 457-8783bhagenbaugh@fsforum.comForum CEO Announces DepartureWashington, D.C. – Financial Services Forum President and CEO Kevin Fromer announced today he plans to depart the organization. He will continue to lead the Forum until a successor is named.Over the past eight years, Fromer has revitalized and refocused the association on behalf of the nation’s eight leading financial institutions to demonstrate their value throughout the economy, educate policymakers about their key priorities, and amplify their direct advocacy as authoritative and reliable industry voices.“I joined the Financial Services Forum nearly eight years ago determined to elevate the understanding and influence of America’s eight leading banks, and to build bipartisan support for policy that would strengthen their ability to serve their customers and fuel the American economy. We have delivered on these goals, with particular impact on major capital rules, including Basel III Endgame. Leading this work, and my excellent team, has been an honor, and now is the appropriate time to welcome another leader who will build on the organization’s tremendous success,” Fromer said.“Under Kevin's leadership, the Forum has been a driving force in uniting our industry and strengthening our voice – providing critical guidance as we all navigated challenges including the regional banking crisis and advocated for revisions to Basel III Endgame. We wish Kevin well as he embarks on his next chapter, and we look forward to building on his vision for the future of the Forum,” said Jane Fraser, Citi CEO and Chair of the Forum’s Board.&nbsp;Fromer joined as Forum President and CEO in 2017. Previously, he was Executive Vice President and Head of Public Affairs for HSBC North America Holdings, and senior advisor to the chief executive of Legg Mason Global Asset Management. Before moving to the private sector, Fromer spent two decades in the U.S. federal government, including as the Senate-confirmed Assistant Secretary of the Treasury for Legislative Affairs.###The Financial Services Forum is an economic policy and advocacy organization whose members are the eight largest and most diversified financial institutions headquartered in the United States. Forum member institutions are a leading source of lending and investment in the United States and serve millions of consumers, businesses, investors, and communities throughout the country. The Forum promotes policies that support savings and investment, financial inclusion, deep and liquid capital markets, a competitive global marketplace, and a sound financial system. Visit our website:&nbsp;<a href="http://www.fsforum.com/">fsforum.com</a>Follow us on X&nbsp;<a href="https://twitter.com/fsforum">@fsforum</a>&nbsp;and&nbsp;<a href="https://www.linkedin.com/company/financial-services-forum/">LinkedIn</a> &nbsp;&nbsp;

Forum CEO Announces Departure

Contact: Laura Peavey&nbsp;&nbsp;(202) 457-8770&nbsp;lpeavey@fsforum.comStress Test Results Confirm Capital Strength of America’s Largest Banks“Forum members have once again proven they are strong, resilient, and can continue to support customers and communities even in the face of a significant economic downturn.”Washington D.C. – Financial Services Forum President and CEO Kevin Fromer issued the following statement today in response to the Federal Reserve Board’s 2025 stress test results:“Today’s results confirm the strong capital positions of the largest U.S. banks.“For over ten years, the largest banks in the nation have consistently demonstrated that their capital levels far surpass the hypothetical losses projected by the Federal Reserve. Forum members have once again proven they are strong, resilient, and can continue to support customers and communities even in the face of a significant economic downturn.“We look forward to the Federal Reserve’s review of capital requirements to help ensure banks can support a strong American economy while maintaining safety and soundness. Further, we appreciate that the Federal Reserve has committed to establish the same transparency and public accountability in the stress tests that are provided for all other capital requirements.”View related&nbsp;<a href="https://fsforum.com/issues/issue-stress-tests">content</a>&nbsp;from the Forum on stress testing.Background:Since 2009, America’s largest banks have tripled their Common Equity Tier 1 capital, the highest quality capital that acts as a buffer against losses.<figure class="image image_resized" style="width:71.77%;"><img src="https://fsforum.com/a/media/cet-1-pic.png"><figcaption>Source: FR Y-9C data, https://www.ffiec.gov/npw/FinancialReport/FinancialDataDownload</figcaption></figure>###The Financial Services Forum is an economic policy and advocacy organization whose members are the eight largest and most diversified financial institutions headquartered in the United States.&nbsp; Forum member institutions are a leading source of lending and investment in the United States and serve&nbsp;millions of consumers, businesses, investors, and communities throughout the country. The Forum promotes policies that support savings and investment, financial inclusion, deep and liquid capital markets, a competitive global marketplace, and a sound financial system. Visit our website:&nbsp;<a href="http://www.fsforum.com/">fsforum.com</a>Follow us on X&nbsp;<a href="https://twitter.com/fsforum">@fsforum</a>&nbsp;and&nbsp;<a href="https://www.linkedin.com/company/financial-services-forum/">LinkedIn</a>

Stress Test Results Confirm Capital Strength of America’s Largest Banks

<h3>Introduction</h3>This week, the Federal Reserve Board, OCC and FDIC issued a proposal to reform the supplementary leverage ratio (SLR).&nbsp; Reform of the SLR has been anticipated for years – ever since the Federal Reserve <a href="https://www.federalreserve.gov/newsevents/pressreleases/bcreg20210319a.htm">committed</a> to propose permanent reform during the COVID pandemic when the deficiencies &nbsp;of the SLR became all too apparent.&nbsp; The proposal and comments from several Fed board members lay out a balanced and rational analysis for the public to examine and comment on.&nbsp; However, there were also a variety of specious claims about the proposal and its effects, which are important to address promptly.<h3>The Proposal Does Not Significantly Reduce Required Capital for U.S. GSIBs</h3>Some have suggested that the Federal Reserve’s proposal will significantly reduce capital for U.S. GSIBs (all of which are Forum members) by more than 20 percent.&nbsp; This claim is both incorrect and at odds with the Federal Reserve’s own analysis.&nbsp;Capital requirements are applied, first and foremost, at the top-tier holding company level and not at the level of a single subsidiary.&nbsp; This is akin to measuring your financial well-being by considering all of your assets and liabilities.&nbsp; If your 401k retirement savings increases by $100,000 while your house value declines by $10,000 then we should all agree that your total wealth has increased by $90,000 and not fallen by $10,000.At the top-tier holding company level, the Federal Reserve’s own <a href="https://www.federalreserve.gov/aboutthefed/boardmeetings/files/leverage-ratio-memo-20250625.pdf">analysis</a> indicates that the proposal will reduce tier 1 capital by $13 billion or about 1.4 percent.&nbsp; The capital stock at the top-tier holding company is available to absorb any and all losses throughout the entire corporate entity and is the capital level that matters for bank safety and soundness as well as financial stability.&nbsp; To put this into further perspective, the eight GSIBs collectively maintain $1.1 Trillion in tier 1 capital.Indeed, when the Federal Reserve discusses bank capital levels – either in its Financial Stability Report, or its Supervision and Regulation Report, or in its semi-annual testimony to Congress – it generally cites top-tier holding company capital levels.Attempts by some commentators to style the Federal Reserve’s proposal as resulting in a large decline in capital are looking narrowly at bank subsidiary capital levels that do not consider the entirety of the financial resources available to the top-tier holding company.&nbsp;&nbsp;&nbsp; Looking at the complete picture, it is clear that the impact on capital levels would be extremely modest. &nbsp;&nbsp;&nbsp;<h3>The Proposal Improves Incentives to Engage in All Low-Risk Activities – Both Under Normal Conditions and Times of Stress</h3>Another claim made about the proposal is that it won’t improve the incentives to intermediate U.S. Treasury markets&nbsp; - either under normal conditions or in times of stress.&nbsp; This statement ignores both the basic logic behind the proposed reform as well as our lived experience with this part of the capital framework.On the theory side, the logic is clear.&nbsp; A capital rule that charges the same requirement to all assets provides clear disincentives to engage in low-risk assets that provide commensurately lower returns.&nbsp; This is not a complex argument.&nbsp; Anyone who runs a business or makes economic decisions can relate.&nbsp; If the cost of doing a range of different activities does not vary but the benefit is highest for one particular activity which would you choose?&nbsp; The activity with the highest benefit will clearly be chosen among all others.&nbsp; In the case of intermediating the U.S. Treasury market, why should banks engage in that relatively low-risk and low-return business if the capital cost is identical to the cost of making more profitable business loans?&nbsp; Clearly, the effect of a one-size fits all capital requirement like the SLR is to disadvantage relatively low-risk activities such as intermediating the U.S. Treasury market.On the empirical side, the recent lived experience of the COVID pandemic provides a useful laboratory in which to test the theoretical prediction.&nbsp; During the pandemic, one of the most stressful periods in global history, the Federal Reserve temporarily excluded U.S. Treasuries from the SLR computation thereby reducing the binding nature of the SLR.&nbsp; What happened during this stressful period?&nbsp; Significant research including research conducted by economists at the <a href="https://papers.ssrn.com/sol3/papers.cfm?abstract_id=4175429">Federal Reserve</a> and economists at the <a href="https://papers.ssrn.com/sol3/papers.cfm?abstract_id=4175429">Federal Reserve Bank of Boston</a> have convincingly shown that during this stressful period large banks engaged more significantly in the U.S. Treasury market which reduced Treasury market volatility and trading costs.&nbsp; Accordingly, both the theory and practice of economics is fully consistent with the prediction that easing the binding nature of risk-blind leverage requirements will improve bank engagement in low-risk activities during both normal times and periods of stress.Relatedly, some commentators have raised a concern that the recent SLR proposal might simply incentivize large banks to engage in other low-risk activities besides U.S. Treasury market intermediation.&nbsp; It is certainly true that a less binding SLR will improve the incentives for banks to engage in all low-risk activities.&nbsp; We should applaud this development in which markets, rather than government fiat, determine which activities are undertaken by banks for the benefit of the broader economy.<h3>The Proposal is Fully Transparent</h3>Beyond the two arguments above, some have suggested that the Federal Reserve’s SLR proposal is not transparent because it relies on the internationally agreed upon (Basel) GSIB surcharge for each U.S. GSIB (Forum member).&nbsp; In fact, the Basel GSIB surcharge is fully transparent and widely available to the public and has been for years.&nbsp; Each year the Financial Stability Board publishes a <a href="https://www.fsb.org/2024/11/2024-list-of-global-systemically-important-banks-g-sibs/">list</a> of global GSIBs along with the corresponding Basel GSIB surcharge level.&nbsp; Further, the Office of Financial Research (OFR) maintains a public <a href="https://www.financialresearch.gov/bank-systemic-risk-monitor/">website</a> that is devoted to tracking Basel GSIB surcharges for all global banks.&nbsp; Finally, the Federal Reserve itself collects and makes public all of the data that is needed to calculate the Basel GSIB surcharges.&nbsp; Accordingly, there is no reasonable sense in which tailoring the SLR to each bank’s Basel GSIB surcharge is anything but fully transparent.<h3>Conclusion</h3>Years ago, the Federal Reserve committed itself to reconsider the SLR in light of its increasingly binding nature that was brought on by long-lived and active policy choices of the Federal Reserve and the U.S. government during the pandemic.&nbsp; The Federal Reserve and other agencies have now made good on this promise. The proposal represents an important first-step in improving the large bank capital regime.&nbsp; The proposal does not, however, significantly reduce large bank capital, frustrate incentives to intermediate the U.S. Treasury market, or reduce the transparency of large bank capital regulation.&nbsp; Any such claims are both misleading and demonstrably false. &nbsp;&nbsp; &nbsp;&nbsp;&nbsp;&nbsp;&nbsp;&nbsp;&nbsp;&nbsp;&nbsp;&nbsp;&nbsp; &nbsp;&nbsp;&nbsp;

A Level Set on the Proposal to Reform the Supplementary Leverage Ratio 

Contact: Laura Peavey&nbsp;&nbsp;(202) 457-8770&nbsp;lpeavey@fsforum.comForum Applauds Efforts to Improve Functioning of Vital Treasury Markets&nbsp;“Forum appreciates regulators taking the first step to ensure the leverage ratio works for the American economy, not against it.”Washington D.C. – Financial Services Forum President and CEO Kevin Fromer issued the following statement after federal regulators released a proposal to update leverage capital requirements:“Addressing longstanding issues caused by outdated leverage capital requirements benefits taxpayers and strengthens the U.S. economy. For years, policymakers across the ideological spectrum have raised concerns regarding the negative impact of this requirement on the U.S. Treasury market—which underpins every other financial asset in the world. Through improvements in leverage capital requirements, America’s leading banks will be better able to support market functions that impact Main Street businesses and consumers across the country. While we look forward to fully reviewing the proposal and providing comprehensive feedback, the Forum appreciates regulators taking the first step to ensure the leverage ratio works for the American economy, not against it.”Read our bank leverage capital requirements fact sheet <a href="https://fsforum.com/a/media/leverage-capital-requirements-factsheet.pdf">here</a>. &nbsp;###The Financial Services Forum is an economic policy and advocacy organization whose members are the eight largest and most diversified financial institutions headquartered in the United States. Forum member institutions are a leading source of lending and investment in the United States and serve millions of consumers, businesses, investors, and communities throughout the country. The Forum promotes policies that support savings and investment, financial inclusion, deep and liquid capital markets, a competitive global marketplace, and a sound financial system.Visit our website: <a href="http://www.fsforum.com/">fsforum.com</a>Follow us on X <a href="https://twitter.com/fsforum">@fsforum</a> and <a href="https://www.linkedin.com/company/financial-services-forum/">LinkedIn</a>

Forum Applauds Efforts to Improve Functioning of Vital Treasury Markets

Press Releases

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Sean Campbell

Chief Economist, Head of Policy Research

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Increases in capital requirements would harm American households, businesses, and the broader economy. Regulators must carefully consider the economic impact of higher capital requirements, because they affect the whole economy, not just banks.

Capital, other topics

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Each year, the Federal Reserve tests the ability of large banks to continue to support the economy even in the face of a severe recession far worse than that experienced during the financial crisis.

Multiple hypothetical stress tests, as well as the real-life stress tests of the pandemic and the 2023 regional banking turmoil, have shown that the largest U.S. banks can – and do – act as a bulwark for the economy and the financial sector.

Stress Tests

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Citigroup

Jane Fraser is the Chief Executive Officer of Citi, the world's most global bank, serving millions of consumers, businesses and institutions across 160 countries and jurisdictions. She is the first female CEO in the firm’s history. Jane has deep experience across Citi’s consumer and institutional businesses and, in many ways, she helped shape Citi into the company it is today. Before becoming CEO in February 2021, she was President of Citi and CEO of the Global Consumer Bank, responsible for all of Citi’s Consumer businesses, including Retail Banking and Wealth Management, Credit Cards, Mortgage and Operations and Technology in 19 markets. Before that, she was the Chief Executive Officer of Citigroup Latin America from 2015 to 2019. From 2013 to 2015, she was the Chief Executive Officer of the U.S. Consumer and Commercial Banking and CitiMortgage. From 2009 to 2013, Jane served as the Chief Executive Officer of Citi's Global Private Bank. Prior, Jane was the Global Head of Strategy and Mergers &amp; Acquisitions for Citi from 2007 to 2009. She joined Citi in 2004 in the Corporate and Investment Banking division. Before joining Citi, Jane was a Partner at McKinsey &amp; Company. She started her career at Goldman Sachs in the Mergers &amp; Acquisitions department in London and then worked for Asesores Bursátiles in Madrid, Spain. Jane serves as a Board Member for the Business Roundtable and the Council on Foreign Relations. She is Vice Chair for the Partnership for New York City and a member of Harvard Business School’s Board of Dean’s Advisors, the Stanford Global Advisory Board and the Economic Club of New York. Jane has an M.B.A. from Harvard Business School and an M.A. in economics from Cambridge University. She is married with two children.

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Jane Fraser

Citigroup Chief Executive Officer, Forum Chair

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BNY 

Robin Vince is President and Chief Executive Officer of BNY and a member of its Board of Directors. Previously, he was Vice Chair of BNY and CEO of Global Market Infrastructure. In that role, he oversaw BNY’s Clearance and Collateral Management, Treasury Services, Markets and Execution Services and Pershing businesses. Prior to joining BNY in October 2020, Robin was the Chief Risk Officer of Goldman Sachs and a member of the Management Committee. He joined Goldman Sachs in 1994 and held many leadership roles, including Treasurer, Head of Operations, Head of Global Money Markets, COO of the EMEA region and CEO of Goldman Sachs International Bank, among others. He served on several key subsidiary boards and governance committees. He was named managing director in 2002 and partner in 2006. Robin is a member of National Geographic Society's Hubbard Council and serves on the Board of Advisors of The Hospital for Special Surgery.

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Robin Vince 

BNY Chief Executive Officer, Forum Vice Chair

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Bank Of America

Brian Moynihan leads a team of more than 200,000 employees dedicated to making financial lives better for people, companies of every size, and institutional investors across the United States and around the world. Bank of America is recognized as a top employer by Working Mother magazine and Military Times. The company is also listed on Fortune magazine’s list of the Best Workplaces for Diversity and the Best Workplaces for Parents. It was also named one of the Best Places to Work for Disability Inclusion by the U.S. Business Leadership Network and the American Association of People with Disabilities. In 2018, Euromoney recognized Bank of America as the World’s Best Bank and the World’s Best Bank for Diversity and Inclusion, as part of their annual Global Awards for Excellence. Bank of America was also named the 2019 Catalyst Award winner, honored for supporting the continued development, empowerment and advancement of women in the company and around the world. Moynihan participates in several organizations that focus on economic and market trends, including the World Economic Forum International Business Council, the Financial Services Forum, the Bank Policy Institute (chair), the Business Roundtable, and the American Heart Association CEO Roundtable (co-chair). He is also a member of the Federal Advisory Council of the Federal Reserve Board. Moynihan leads the company’s Global Diversity and Inclusion Council and is a member of the museum council for the Smithsonian’s National Museum of African American History and Culture. Moynihan is also a member of the Brown University Corporation’s Board of Fellows and the Congressional Medal of Honor Foundation Board.

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Brian Moynihan

Bank Of America Chairman Of The Board And Chief Executive Officer

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The Goldman Sachs Group, Inc.

David Solomon is Chairman and Chief Executive Officer and a member of the Board of Directors of The Goldman Sachs Group, Inc. Previously, he was President and Chief Operating Officer and prior to that, he served as Co-Head of the Investment Banking Division from 2006 to 2016. Before that, Mr. Solomon was Global Head of the Financing Group, which includes all capital markets and derivative products for the firm’s corporate clients. He joined Goldman Sachs as a Partner in 1999. Mr. Solomon is a member of the Board of Trustees of Hamilton College and serves on the board of The Robin Hood Foundation.

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David Solomon

The Goldman Sachs Group, Inc. Chairman and Chief Executive Officer

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JPMorganChase 

Jamie Dimon is Chairman of the Board and Chief Executive Officer of JPMorganChase, a global financial services firm with assets of $2.5 trillion and operations worldwide. The firm is a leader in investment banking, financial services for consumers, small business, commercial banking, financial transaction processing and asset management. Dimon became CEO on January 1, 2006 and one year later also became Chairman of the Board. He was named President and Chief Operating Officer upon the company’s merger with Bank One Corporation on July 1, 2004. Dimon joined Bank One as Chairman and CEO in 2000. Dimon began his career at American Express Company. Next, he served as Chief Financial Officer and then President at Commercial Credit, which made numerous acquisitions and divestitures, including acquiring Primerica Corporation in 1987 and The Travelers Corporation in 1993. Dimon served as President and Chief Operating Officer of Travelers from 1990 through 1998 while concurrently serving as Chief Operating Officer of its Smith Barney Inc. subsidiary before becoming co-Chairman and Co-CEO of the combined brokerage following the 1997 merger of Smith Barney and Salomon Brothers. In 1998, Dimon was named President of Citigroup Inc., the global financial services company formed by the combination of Travelers Group and Citicorp. Dimon earned his bachelors degree from Tufts University and holds an MBA from Harvard Business School. He serves on the boards of directors of a number of non-profit institutions including the Clearing House and Harvard Business School. Additionally, he is the Chairman of the Business Roundtable and serves on the executive committee of the Business Council and the Partnership for New York City, and is a member of the Financial Services Forum, Financial Services Roundtable and Council on Foreign Relations.

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Jamie Dimon

JPMorganChase Chairman And Chief Executive Officer

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Morgan Stanley

Edward (Ted) Pick is the Chief Executive Officer of Morgan Stanley.Before becoming CEO in 2024, Mr. Pick served as Morgan Stanley's Co-President, Co-Head of Firm Strategy and Head of the Institutional Securities Group, overseeing Investment Banking, Equities, Fixed Income, Global Capital Markets and Research.&nbsp;In previous roles, Mr. Pick was Global Head of Sales and Trading, engineering a turnaround of the firm’s Fixed Income Division. As Head of Institutional Equities, he led that business to a leading global position. He also served as Head of Equity Capital Markets, helping the firm actively raise capital during the financial crisis.&nbsp;Mr. Pick joined Morgan Stanley in 1990 and was promoted to Managing Director in 2002. He is a member of the firm’s Board of Directors (2024), Operating Committee (2012), Management Committee (2008) and Morgan Stanley-MUFG Steering Committee (2013).Mr. Pick graduated Phi Beta Kappa from Middlebury College (1990) and received an MBA from Harvard Business School (1994). He is a Trustee at the Metropolitan Museum of Art (2018), and serves on the MET’s Nominating &amp; Governance Committees. Mr. Pick is Chair of the Advisory Board for the Morgan Stanley Alliance for Children’s Mental Health and a board member of the Institute of International Finance.

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Ted Pick

Morgan Stanley Chief Executive Officer

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State Street Corporation

Ron is chairman and chief executive officer of State Street Corporation. He is also a member of State Street Corporation’s Board of Directors. Ron was previously president and chief operating officer of State Street Corporation, and before that president and chief executive officer of State Street Global Advisors, the investment management arm of State Street Corporation. He joined State Street in 2015. Prior to State Street, Ron was president of Asset Management &amp; Corporate Services for Fidelity Investments, responsible for all Fidelity asset management organizations and Fidelity’s corporate functions and enterprise technology. He served at Fidelity from 2010 to 2014. Prior to joining Fidelity, Ron served as president and chief executive officer of BNY Mellon Asset Management in Boston, a position to which he was named in 2007. During this time, he also served as vice chairman of Bank of New York Mellon Corporation and was a member of its Executive Committee. Additionally, Ron oversaw all of Bank of New York Mellon’s activities in Asia. Prior to the 2007 merger of Bank of New York and Mellon, he was vice chairman of Mellon Financial Corporation and president and chief executive officer of Mellon Asset Management. He served at Mellon and Bank of New York Mellon from 1997 to 2010. Prior to Mellon, Ron was with McKinsey &amp; Company, Inc., from 1986 to 1997 and was elected a partner in 1992. He founded the Investment Management practice worldwide and was co-founder and co-leader of the firm’s North American Personal Financial Services practice. Additionally, he was a member of the Worldwide Property &amp; Casualty Insurance practice. During his tenure with McKinsey, Ron served in the firm’s Boston, New York, and Stockholm offices. Ron received his Bachelor of Arts degree in political science from Syracuse University in 1980 and his Master of Business Administration from Harvard Business School in 1986. Ron serves on the boards of Unum Corp. and Rhode Island Commerce Corporation. He also serves on the boards of Beth Israel Lahey Health, The Boston Foundation, IYRS School of Technology and Trades, Syracuse University and WBUR. Ron’s philanthropic and civic interests include corporate governance, retirement/healthcare policy and funding, education, and climate. He has led several initiatives on gender equality. Ron is a frequent speaker and writer, and an avid offshore sailboat racer.

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Ronald O'Hanley

State Street Corporation Chairman And Chief Executive Officer

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Wells Fargo & Company

Charles W. Scharf is chief executive officer and president, and a member of the Board of Directors of Wells Fargo &amp; Company. A financial services veteran with 24 years of experience in leadership roles in the banking and payments industries, Charlie served as chief executive officer of Bank of New York Mellon from July 2017 to October 2019 and the chairman of its board from January 2018 to October 2018. He also was chief executive officer and a director of Visa Inc. from October 2012 to December 2016. During his tenure at Bank of New York Mellon, Charlie demonstrated a strong track record in initiating and leading change, driving results, strengthening operational risk and compliance, and innovating amid a rapidly evolving digital landscape. As the CEO of Visa, Charlie transformed the firm into a technology-driven digital commerce company by partnering with the world’s leading technology companies to drive new payment experiences and introduce new technologies to improve payment system security. Previously, he was a managing director of One Equity Partners at JPMorgan Chase &amp; Co. and chief executive officer of Retail Financial Services at JPMorgan Chase. He also was chief executive officer of the retail division of Bank One Corp., chief financial officer of Bank One Corp., chief financial officer of the Global Corporate and Investment Bank division of Citigroup, and chief financial officer of Salomon Smith Barney and its predecessor company. Charlie earned a Bachelor of Arts degree from Johns Hopkins University and an MBA from New York University. He is a director of Microsoft Corporation, serves on the board of trustees of Johns Hopkins University, is a member of The Business Council, and is chairman of the New York City Ballet. He lives in New York City.&nbsp;

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Charles Scharf

Wells Fargo & Company Chief Executive Officer And President

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We are the eight largest and most diversified financial institutions headquartered in the United States. Our more than 712,269 U.S. employees&nbsp;serve millions of consumers, businesses, investors, and communities across the country.

Forum members increased credit to businesses and households by 17% to $9.3 trillion in 2021.

Despite the demonstrated strength of the largest U.S. banks, the Federal Reserve, Federal Deposit Insurance Corporation, and the Office of the Comptroller of the Currency, on split votes, issued a proposal in July 2023 to increase capital requirements. The proposal offers no reason or justification for material increases in capital requirements and would harm American households, businesses, and the broader economy. 

Given the complexity of the proposal, its many and significant negative impacts, and the lack of evidence in support of its changes, the agencies should repropose the rule and include the motivations, data and analysis that demonstrate the need for proposed changes.

Basel 3 Endgame 

The nation’s largest banks are subject to the most stringent liquidity standards among U.S. banks. These standards ensure that the largest U.S. banks have sufficient liquid resources, such as cash, to meet liquidity needs such as when customers withdraw money from their accounts. Since 2009, the U.S. GSIBs have tripled their liquid assets, allowing them to remain strong and continue to lend and support the economy in the face of headwinds.

Liquidity 

Maintaining the international competitiveness of U.S. companies is vital to the success and vibrancy of the U.S. economy. The nation’s largest banks provide crucial support for American companies competing overseas. The Forum supports policies that enable large U.S. banks to continue their vital support of the American economy on the global stage. 

International Competitiveness

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Covid-19 Response

The COVID-19 pandemic is an unprecedented challenge for the world and the global economy and the largest U.S. banks are committed to supporting customers, clients, and the nation.

PPP loans from JPMorgan have supported 3 million workers at small businesses, including those working at Community Wellness Ventures, a mental health services company that serves children and families in Washington, D.C. The PPP loan has helped Dr. Charlayne Hayling-Williams and her husband, Dr. Rod Williams, continue to pay their counselors, social workers, psychologists and housing specialists so that they can continue to serve their community.The majority of Citibank’s PPP loans went to small businesses in the service sector. A PPP loan from Citi helped the Maryland Youth Ballet in Silver Spring retain teaching staff and find a way to teach students safely and retain employees. The students range in age from 2 to 19 years old. “If we hadn’t been able to receive this PPP loan, we wouldn’t be able to keep dancing,” Principal Deidre Byrne says. <a href="https://www.youtube.com/watch?v=dMzepw_oAtQ&amp;feature=youtu.be">Learn more</a>.State Street is a lead sponsor of <a href="https://www.smallbstrong.com/">Small Business Strong</a>, a non-profit organization helping women and minority owned small businesses navigate the devastating impact of the COVID-19 pandemic. Small Business Strong provides expedited, pro-bono resources to small businesses ranging from access to capital to consulting, business restructuring, business growth, digital marketing and customer engagement plans.Another way Forum banks have worked to assist small businesses is by supporting financial institutions with particularly strong connections to certain local communities. Forum banks have increased their support for Community Development Financial Institutions (CDFIs) during the pandemic. CDFIs are private financial institutions that are dedicated to providing responsible, affordable lending to help low-income and typically underserved communities. From 2015 to 2020, <a href="https://www.fsforum.com/wp-content/uploads/2021/01/cdfifactsheetfinal2021.jpg">Forum banks have invested nearly $9 billion in CDFIs.</a> Through such assistance, Forum member banks are working to ensure that small businesses in these communities get the help they need.Goldman Sachs last year committed $1 billion to support lending through CDFIs and other mission-driven lenders. More than 15,000 small businesses with 87,000 employees were supported just partway through the commitments. Nearly half of the initial funds went to businesses in minority communities; one-third went to those in low-income communities. <a href="https://www.forbes.com/sites/maneetahuja/2020/12/15/goldman-sachs-ceo-david-solomon-announces-additional-250-million-investment-in-small-businesses-bringing-total-2020-commitment-to-1-billion/?sh=3739ddc91000">Read more</a>.

Members of the Financial Services Forum have supported small businesses across the country throughout the pandemic, helping provide important resources during a challenging time for many business owners and their employees.

Throughout the pandemic, Forum members facilitated $94 billion in loans to nearly 1.25 million small businesses through the government Paycheck Protection Program. More than a quarter of these loans were made in low- and moderate-income communities and 91 percent of the PPP loans made by Forum members went to businesses with 20 or fewer employees.

At the beginning of 2020, Morgan Stanley launched the <a href="https://www.morganstanley.com/articles/alliance-for-childrens-mental-health-covid-19">Morgan Stanley Alliance for Children’s Mental Health</a> to help address children’s mental health, specifically the far-reaching challenges of stress, anxiety and depression. After the COVID-19 pandemic began, Morgan Stanley made an additional grant to the Child Mind Institute to provide digital mental health resources for children, adolescents and young adults, with a focus on vulnerable communities that traditionally lack access to these resources.Among other areas of focus, the Alliance is promoting public awareness of how the COVID-19 pandemic affects children’s mental health—both now and in the long term.In addition to providing relief to millions of customers, Wells Fargo has redirected millions of dollars from its philanthropic budget to COVID‑19 community relief efforts for the most impacted Americans. The company has worked to streamline grant making and offer highly flexible funding to nearly 1,000 nonprofits reaching more than 800 communities across the country.The program is making a difference in helping those who need it most access small business resources, stay in their homes and obtain financial health resources. In Alabama, a $100,000 grant to the Birmingham Strong Fund is providing emergency loans to small businesses to help stabilize employment, stimulate economic vitality, and offset losses related to COVID‑19. A $100,000 grant to United Way of Greater Los Angeles has helped the group create the Pandemic Relief Fund to support vulnerable populations who are at the greatest risk of health and economic impacts in this crisis. A $160,000 grant to the Institute of Community Alliances is providing rental assistance to shelter residents across the state of Iowa.Bank of America in 2020 announced a $1 billion, four-year commitment of additional support to help local communities address economic and racial inequality accelerated by the global pandemic. The programs are focused on assisting people and communities of color that have experienced a greater impact from the health crisis in areas that include:<ul><li>Virus testing, telemedicine, flu vaccination clinics, and other health services, with a special focus on communities of color.</li><li>Partnerships with historically black colleges and universities and Hispanic-serving institutions in the United States for hiring, research programs, and other areas of mutual opportunity.</li><li>Support to minority-owned small businesses, including clients and vendors.</li><li>Career reskilling/upskilling through partnerships with high schools and community colleges.</li><li>Operating support and investment for affordable housing/neighborhood revitalization, leveraging the company’s nearly $5 billion in Community Development Banking.</li><li>Further recruitment and retention of teammates in low- to moderate-income and disadvantaged communities to build on work the company has already done to serve clients locally.</li></ul>

Forum members have collectively committed billions of dollars to communities in need. This aid is helping organizations and governments increase medical response capacity, address food insecurity, increase access to education in the face of school closures, protect impacted small businesses and provide support to the vulnerable populations.

Financial support is being dispersed to a number of organizations and programs such as the World Health Organization’s COVID-19 Solidarity Fund, the CDC Foundation, No Kid Hungry, Feeding America, National Centers for Disease Control and Prevention’s Emergency Relief Fund, the International Medical Corps and many other community-specific groups.

Forum members have been supporting their customers in a variety of ways, including by providing fee waivers, payment deferrals, and other assistance to help customers in need, with no negative credit bureau reporting for up-to-date clients.

Another key way in which large banks are serving households is the provision of safe, secure deposit accounts. 

People use deposit accounts as a safe store of value during uncertain times. With general economic uncertainty and an increase in market volatility, people are relying more on safe, liquid, bank deposits as they manage a variety of near-term risks. 

As people demand a safe store of value for their hard-earned money, Forum members have provided this critical service. Forum members provide depositors with a range of online services to access their deposits remotely, which are all the more valuable as people practice social distancing. 

Since the start of the crisis, <a href="https://www.bnymellon.com/us/en/insights/content-series/covid-19.html">Bank of New York Mellon</a> has worked to support its employees and their families with a number of actions and programs. The bank has provided paid leave benefits and an Employee Assistance Program for all employees and their direct family members, including a 24/7 COVID-19 support line. It is providing enhanced U.S. healthcare coverage so that COVID-19 testing and related outpatient services are provided without any employee out-of-pocket expense. The firm has also provided a 2-for-1 match for employee donations.

Forum members are actively helping ensure the health and well-being of their more than 720,000 employees. 

From special compensation awards, to additional time off, to counseling services, the nation’s largest banks have been taking significant steps to support their workforces.

In 2020, Forum member institutions:<ul><li>Increased credit to businesses and households by $785 billion to nearly $8.3 trillion.</li><li>Helped raise $2.2 trillion in corporate bonds and $339 billion in equity through the third quarter for U.S. companies, allowing them to continue to pay their workers, operate their businesses and meet their funding needs. This capital raising by large banks fulfills a critical need in the economy to connect savers, such as pension funds and endowments, with companies like Pfizer and 3M that need to borrow capital for everyday business needs. <a href="https://www.fsforum.com/types/press/blog/building-bridges-between-savers-and-borrowers-during-the-pandemic-large-bank-underwriting/">Read more</a>.</li><li>Remained strong and resilient, despite the significant headwinds. The members of the Financial Services Forum in 2020 increased capital and strengthened their liquidity positions while at the same time supporting business and consumers.</li></ul>

Forum member institutions have been a key source of support for the economy during the pandemic. They have supported the economy in a number of important ways.



Throughout the pandemic, we facilitated $94 billion in PPP loans to nearly 1.25 million small businesses across the country.

COVID-19 Response

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<ul><li>We hold more than $4.2 trillion in loans, accounting for 40% of total lending to businesses and households.</li><li>We provide more than $679 billion, or nearly half, of all consumer loans by banks in the U.S., supporting everything from the purchase of a new car to furnishing a new home.</li><li>Lending by our institutions accounts for 34% of total commercial and industrial (C&amp;I) lending by banks, helping businesses grow and contribute to the economy.</li><li>We represent a major source of lending to small businesses in communities across the country, holding $126 billion in small business loans&nbsp;and allowing the economy to grow at both a local and national level.</li><li>We also collectively meet nearly three-quarters of the bank funding needs of other financial institutions, supporting community banks, insurance companies and mortgage finance companies, for example, which then provide important services to businesses and households.</li></ul>

Our institutions lend to consumers, businesses and other financial institutions, promoting savings and investment that positions individuals and entities at all layers of the U.S. economy for resiliency and success. At the same time, we are supporting consumers, governments, and businesses of all sizes in growing and creating American jobs.

<ul><li>We underwrite nearly three-quarters of debt and equity transactions – such as initial public offerings – among large institutions in the U.S., providing a critical service that other U.S. institutions cannot offer on a similar scale.</li><li>With $4.2 trillion of mutual funds and annuities under management, we support the retirement and other savings needs of many Americans.</li><li>We finance a significant portion of state and local government expenditures for vital projects, like hospitals, roads, bridges, and schools, through $120 billion in municipal securities holdings. Additionally, we support a large portion of federal government expenditures through $1.1 trillion in U.S. Treasury securities holdings.</li></ul>

Our institutions help foster deep and liquid capital markets, ensuring the U.S. government and private institutions are able to effectively finance public spending and investments in the real economy. 

Our institutions collectively employ more than 750,000 people, offering a variety of benefits and opportunities to help our employees achieve their personal and professional goals.

Forum members increased credit to businesses and households by 10%
to nearly $8.3 trillion in 2020.


Essential to the U.S. Economy    

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Forum members have long been on the frontlines in the effort to bring unbanked and underbanked Americans into the financial mainstream. In particular, Financial Services Forum members were founding bank partners in a pilot program to provide low-cost, low-fee checking accounts, known as BankOn accounts, nearly a decade ago. There are now 12 million BankOn accounts at Forum member banks across the country. Our members will continue to be leaders in this effort to bring even more households into the banking system so they can help secure their financial future.

Forum members are playing a leading role in promoting affordable housing throughout the country. In 2023, Forum banks created or preserved nearly a quarter of a million affordable housing units.

We are supporting hundreds of Community Development Financial Institutions (CDFIs) and Minority Depository Institutions (MDIs) by providing over $11.5 billion in capital and financing since the beginning of 2020.

Our members recognize that talent from all backgrounds bolsters competitiveness, and leads to better results for consumers, clients, and communities. Forum members are committed to providing opportunities to workers from across the country and fostering their success through professional development, networking, and support programs. 

We invested more than $11.5 billion in Community Development Financial Institutions since the beginning of 2020. 

Economic Opportunity for all Americans

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America’s leading banks support Main Street by deploying nearly $5 trillion in loans to businesses and families across the country, in addition to helping people save for the future. Forum members play a critical role in the growth and success of the U.S. economy by serving consumers, partnering with small businesses, and lending to other financial institutions. We are also uniquely positioned to support states and localities raise the funds they need to build and upgrade vital infrastructure, like hospitals, schools, roads, and bridges.

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