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CONTACT: Barbara Hagenbaugh(202) 471-0436bhagenbaugh@fsforum.com&nbsp;“There is no compelling case to increase capital requirements at the largest banks,” Forum CEO saysWashington, D.C. – Financial Services Forum President and CEO Kevin Fromer issued the following statement today on large bank capital:“We look forward to seeing the conclusions drawn from the Federal Reserve’s holistic capital review.&nbsp;The banking system has evolved significantly from the financial crisis.&nbsp;Capital levels at our largest banks are at historic highs. Indeed, the nation’s largest banks have performed well in repeated government stress tests – which assume no government support – and in the real-life stress test of the pandemic. &nbsp;“There is no compelling case to increase capital requirements at the largest banks, which would raise the costs of lending for families and businesses, hinder U.S. economic growth, and further push activity outside of the regulated financial sector. Regulators must carefully consider the economic impact of capital requirements, because they affect the whole economy, not just banks.”&nbsp;&nbsp;Background:Capital requirements for the eight U.S.-based Global Systemically Important Banks (GSIBs) that comprise the Forum have increased substantially and are continuing to rise. Since 2009, Forum members have increased their Tier 1 capital by 49 percent from $655 billion to $979 billion. This strength positioned them during and after the pandemic – a real-life stress test – to support individuals, small businesses, major companies, and communities across the country.Read more about capital at the nation’s largest banks in this <a href="https://fsforum.com/a/media/capital-and-the-nation%E2%80%99s-largest-banks.pdf">fact sheet</a> and in the Forum’s BankNotes <a href="https://fsforum.com/news/category/banknotes-blog/1/9">blog</a> series, including the <a href="https://fsforum.com/news/don-t-paint-the-house-before-finishing-the-roof-basel-iii-finalization-and-the-large-bank-capital-regime">latest post</a>, <a href="https://fsforum.com/news/don-t-paint-the-house-before-finishing-the-roof-basel-iii-finalization-and-the-large-bank-capital-regime">Don’t Paint the House Before Finishing the Roof: Basel III Finalization and the Large Bank Capital Regime</a>.&nbsp;###&nbsp;The Financial Services Forum is an economic policy and advocacy organization whose members are the chief executive officers of 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. &nbsp;Follow us on Twitter <a href="https://twitter.com/fsforum">@fsforum</a> and <a href="https://www.linkedin.com/company/financial-services-forum/">LinkedIn</a>

Capital Requirements Affect the Entire Economy, Not Just Banks

<h3>Introduction</h3>Recently, the Federal Reserve indicated that banking regulators will soon release a proposal to implement a further revision to the large bank capital framework, known as Basel III Finalization.&nbsp; This “final” round of Basel reforms is often described as putting the “finishing touches” on the Basel III capital regime.&nbsp; Unfortunately, there are bigger and more consequential open issues with the current large bank capital regime that should be addressed before any “finishing touches” are considered.&nbsp; Moving ahead with Basel III Finalization before addressing these more fundamental concerns would be akin to painting the exterior of a new house before the roof has been finished.&nbsp; A house with a beautiful exterior that floods whenever it rains may have lots of curb appeal and may please the neighbors, but isn’t very functional for its inhabitants. &nbsp;In this post, we discuss the state of the large bank regulatory regime and review some important and long-standing concerns that should be addressed before moving ahead with Basel III Finalization.&nbsp;&nbsp;&nbsp;<h3>The Basel Process is Broken and Must Be Reformed</h3>Basel III Finalization is part of a broader, international standard-setting process in which regulators around the globe negotiate capital standards for internationally active banks.&nbsp; The underlying rationale for global coordination of capital policy is that banking is a global business and even small differences in capital regulation can drive large and destabilizing changes in banking activity.&nbsp; The Basel Committee on Banking Supervision (BCBS) has been setting global capital standards since 1988, but recent events strongly suggest a fundamental breakdown in the process that runs counter to the BCBS’s raison d’etre: globally coordinated and consistent bank capital requirements.Specifically, the European Union (EU) has <a href="https://www.bloomberg.com/news/articles/2022-11-07/eu-set-to-water-down-plan-for-new-bank-capital-standards?sref=DbQo3YbX">proposed</a> implementing Basel III Finalization in a way that significantly deviates from some of its key provisions and would lower the amount of capital required for EU banks relative to the amount that will be required of other banks implementing the reforms. European members of the Basel Committee have warned that this departure will “risk undermining global cohesion.” But this is not the first instance in which the EU banking sector has played by its own rules.&nbsp; Leading examples include not implementing other aspects of the <a href="https://www.risk.net/derivatives/7948491/jpm-eu-corporate-cva-exemption-could-split-swaps-liquidity">Basel III reforms</a> as well as recent EU-led changes to the GSIB surcharge methodology specifically designed to benefit certain <a href="https://fsforum.com/news/the-unlevel-playing-field-gets-even-steeper-changes-to-the-gsib-surcharge-for-european-banks-and-implications-for-the-united-states">EU banks</a>.&nbsp;&nbsp;&nbsp;This breakdown in the Basel process is fundamentally concerning and should be addressed before any additional Basel reforms are implemented in the U.S. Continued implementation of Basel capital reforms that are implemented differently would likely mean that capital requirements for U.S. banks would be raised while other banks around the world would not face the same increases. That would result in increased competitive inequities that undermine, rather than strengthen, the global capital framework.<h3>Large U.S. Banks Are Already Highly Capitalized</h3>The Basel III Finalization package is expected to raise capital requirements for large U.S. banks.&nbsp; Indeed, the EU deviations described above are motivated by the desire of the EU to soften the blow of the oncoming increases in capital requirements for European banks.&nbsp; Before moving ahead with Basel III Finalization, policymakers should consider one basic question: Do U.S. banks need additional capital and if so, why?The data and experience with respect to large bank capital levels is clear.&nbsp; Large banks have substantially raised their capital levels - both in absolute dollar terms and in proportion to their risk-weighted assets - over the past 15 years as shown in the figure below.&nbsp; In addition, as noted of large banks in the Federal Reserve Board’s most recent <a href="https://www.federalreserve.gov/publications/files/202211-supervision-and-regulation-report.pdf">Supervision and Regulation Report</a>, “recent stress test results suggest that these firms remain sufficiently well capitalized to continue lending to households and businesses in a simulated period of stress.”&nbsp; Finally, the recent real world stress test of the pandemic clearly showed that banks are a source of strength to the economy.&nbsp; Simply put, there is no compelling evidence suggesting that large banks suffer from a dearth of capital.&nbsp;<figure class="image"><img src="https://fsforum.com/a/media/screen-shot-2022-11-14-at-9.55.20-am.png"><figcaption>Source: Federal Reserve Y-9C</figcaption></figure>&nbsp;Capital is not a free resource in the economy.&nbsp; Ever increasing amounts of required capital will continue to <a href="https://fsforum.com/news/bank-capital-borrowing-costs-and-lending-demand-curves-still-slope-downwards">push up the cost of lending</a> and reduce economic growth.&nbsp;<h3>The Existing Large Bank Capital Regime Needs Significant Reform</h3>The Federal Reserve has recently announced a <a href="https://www.federalreserve.gov/newsevents/speech/barr20220907a.htm">holistic review</a> of the large bank capital regime.&nbsp; This review affords bank regulators with an important opportunity to take a step back and assess the current state of large bank regulation.&nbsp; Any reasonable review of the framework will show that there are several aspects of the capital regime in need of structural reform.&nbsp; These structural reforms should be undertaken, completed, and assessed over a period of time before any “finishing touches” are applied.&nbsp; A short list of reform areas would include:Review and recalibrate the GSIB Surcharge – Upon finalizing the GSIB surcharge in <a href="https://www.federalreserve.gov/newsevents/pressreleases/bcreg20150720a.htm">2015</a>, the Federal Reserve committed to periodic reviews of the GSIB surcharge to reflect economic growth.&nbsp; In addition, the pandemic has revealed significant deficiencies with the GSIB surcharge that also need to be addressed.&nbsp; The largest banks have safer balance sheets because of their increased reserve holdings caused by the Federal Reserve’s pandemic response, yet their GSIB capital charges – intended to reflect systemic risk – have increased merely due to the increased amount of those riskless assets.&nbsp; Any legitimate holistic review of the existing large bank capital regime must include a reconsideration and recalibration of the GSIB surcharge.Review and recalibrate the Supplementary Leverage Ratio (SLR) – Over the past few years, and especially since the onset of the pandemic, the SLR has become increasingly binding and has meaningfully contributed to declining liquidity in the U.S. Treasury market.&nbsp; Treasury market functioning has deteriorated so much that the Group of 30 recently <a href="https://group30.org/images/uploads/publications/G30_Treasury-Mkts-UPDATE_Final_Report.pdf">published</a> an update to its 2021 report exhorting regulators to recalibrate the SLR.&nbsp; In addition, recent <a href="https://papers.ssrn.com/sol3/papers.cfm?abstract_id=4175429">research</a> from Federal Reserve economists finds that the SLR materially disincentivizes bank participation in the U.S. Treasury market.&nbsp; In light of the importance of the U.S. Treasury market to the U.S. economy and overall financial stability, it is imperative that regulators act quickly to address this significant problem.Review and reform the stress testing and stress capital buffer (SCB) process – The stress testing process that results in the annual determination of SCBs is opaque and results in substantial year-to-year variation in SCB levels.&nbsp; Over the past three years, the stress testing process has resulted in SCBs that fall by more than half for some while others have nearly doubled from one year to the next.&nbsp; This variability in year-to-year capital requirements injects unnecessary and unhelpful volatility that frustrates good, long-term capital planning.&nbsp; In addition, the opaque nature of the stress tests often produces results that are hard to align with any sensible notion of risk.&nbsp; The stress testing process should be overhauled to improve public transparency and reduce volatility.<h3>Conclusion</h3>Large U.S. banks are well capitalized and are serving our economy well in this period of heightened uncertainty and economic headwinds.&nbsp; There is no compelling evidence to suggest that large U.S. banks are anything but robustly capitalized.&nbsp; Over time, a number of significant and structural shortcomings with the current large bank capital framework have become apparent.&nbsp; These problems have been demonstrated over time and are based on hard facts, data, and research.&nbsp; Regulators should commit to reviewing and addressing these shortcomings before putting further “international” reforms into effect.&nbsp; Finally, the process for international coordination of bank regulation should be overhauled to ensure full coordination and implementation by all parties.&nbsp; A fractured system of coordination in which some countries routinely raise capital standards while others do not will increase, rather than reduce, financial instability and risk.&nbsp;

Don’t Paint the House Before Finishing the Roof: Basel III Finalization and the Large Bank Capital Regime

Dear reader,Welcome to the latest edition of The Forum File. In this edition, we are highlighting our firms’ work to support diversity and inclusion in the banking sector and the communities they serve.We hope you enjoy reading this edition and please do not hesitate to share your feedback.Kevin Fromer, President and CEO, Financial Services Forum&nbsp;<h2>Penny For Your Thoughts</h2>Susan Reid is a Managing Director and the Global Head of Talent at Morgan Stanley and a member of the bank’s Management Committee.<h3>&nbsp;</h3><h3>Tell us about the Morgan Stanley Institute for Inclusion and how it supports the firm’s diversity and inclusion strategy.</h3>At Morgan Stanley, diversity and inclusion is embedded into our culture and is one of our firm’s core values. To further our commitment, we launched the <a href="https://www.morganstanley.com/about-us/diversity/institute-for-inclusion">Institute for Inclusion</a> in June 2020, with the mission to support underserved communities, advance equity through philanthropic giving and drive workplace diversity. The Institute brings our employees, communities and clients together in a shared commitment to creating a more equitable society. Chaired by James Gorman, Morgan Stanley’s Chairman and CEO, and an independent advisory board, the Institute has launched programs to support our diversity and inclusion efforts and played an active role in advising on key issues.Our strategy is designed to support and accelerate diversity and inclusion efforts both within Morgan Stanley and within the communities we serve.&nbsp; We focus on three core pillars to deliver on the Institute’s mission:<ul><li>Workforce: Support and advise on internal diversity, equity and inclusion efforts to enable Morgan Stanley to become a leader in attracting, developing and retaining diverse talent and to create a culture of inclusion.</li><li>Society: Support underserved communities with philanthropy that drives social justice and promotes racial and gender equity with a focus on educational attainment, addressing the racial wealth gap, and health and wellness.</li><li>Marketplace: Invest to advance economic outcomes in underserved communities through our products and business practices.</li></ul><h3>How is the Institute working to advance diversity within the firm?</h3>We continue to develop and invest in internal diversity, equity and inclusion efforts. For example, the Institute’s Talent Accelerator provides a suite of offerings that support career advancement for women and ethnically diverse Vice Presidents and Executive Directors in areas such as skill development, career management, coaching and networking with senior leaders and peers.When it comes to hiring, Morgan Stanley’s Experienced Professionals Program welcomes professionals from a broad range of industries with two or more years of post-graduate work. And at the campus level, we recently welcomed the second cohort of the Morgan Stanley HBCU Scholars Program. This program provides full academic scholarships to 60 students, 15 each year, and represents a $12 million investment and a key element of our expanding portfolio of global scholarships.<h3>What programs have the Institute launched to drive diversity beyond the firm’s walls?</h3>We have a number of innovative programs focused on spurring change in society and the business community more broadly. Our Equity in Education and Career Consortium (EECC) was launched in 2021, with an initial commitment of $20 million, to help address systemic inequities for young adults from low- to moderate-income backgrounds (see more in Value Add below). And in September, we announced the inaugural winners of the&nbsp;<a href="https://cts.businesswire.com/ct/CT?id=smartlink&amp;url=https%3A%2F%2Fwww.sjiawards.org%2F&amp;esheet=52930155&amp;newsitemid=20220929005552&amp;lan=en-US&amp;anchor=Social+Justice+Innovation+Awards&amp;index=1&amp;md5=e0f524dfc05d0190cd7863547f3fcd6f">Social Justice Innovation Awards</a> in partnership with Centri Tech Foundation. This initiative aims to advance social and racial justice and help drive greater inclusive economic opportunity, providing five organizations with $250,000 each to support their game-changing work to advance systemic solutions to complex social justice issues.Finally, we are looking forward to welcoming the next cohort of The Morgan Stanley Small Business Academy in 2023. This program, launched in spring 2022, promotes equity and empowering diverse-owned small-business leaders through education, sharing best practices, and mentorship. The Academy focuses on helping small businesses leverage their competitive advantage, differentiate themselves in the procurement process, strengthen their business knowledge, and build their professional network.&nbsp;<h2>Value Add</h2>&nbsp;<figure class="image"><img src="https://fsforum.com/a/media/asap_c-morganstanley_s.jpeg"></figure>&nbsp;Recognizing that there is much work to be done in expanding access to education, Morgan Stanley launched the Equity in Education and Career Consortium (EECC) at the end of 2021. Funded with an initial commitment of $20 million to be used over five years, the EECC helps to address systemic inequities for young adults from low- to moderate-income backgrounds. In partnership with the <a href="https://www.morganstanley.com/about-us/giving-back">Morgan Stanley Foundation</a>, the initiative convenes a consortium of organizations that already have proven track records in helping high school and college students achieve stronger education and career outcomes.The EECC will impact more than 30,000 students globally, many of whom are the first generation in their families to attend college. Our objective is to level the playing field by exposing students to career paths and opportunities that might not be visible in their communities; broadening students’ skills through training and mentorship; and creating a lasting support system as these students embark on their academic and career journeys.This initiative highlights not only our own efforts to create a more equitable society, but also our understanding that we cannot achieve this goal alone. We have brought on College Possible and CUNY ASAP and invested $5.5 million to provide similar support for community college students. Together as a team, we will focus on eliminating barriers to degree completion and try to ensure that young adults graduate college with the tools, mindsets and self-confidence they need to enter the workforce. Learn more about the EECC <a href="https://www.morganstanley.com/press-releases/equity-in-education-and-career-outcomes-">here</a>.&nbsp;<h2>Capital Gains</h2>What we’re doing in Washington&nbsp;The Forum issued a <a href="https://fsforum.com/news/capital-requirements-affect-the-entire-economy-not-just-banks">statement</a> on large bank capital, emphasizing that the nation’s largest banks are well-capitalized and urging regulators to carefully consider the effects that increased capital requirements would have on the economy: “There is no compelling case to increase capital requirements at the largest banks, which would raise the costs of lending for families and businesses, hinder U.S. economic growth, and further push activity outside of the regulated financial sector. Regulators must carefully consider the economic impact of capital requirements, because they affect the whole economy, not just banks.”&nbsp;&nbsp; &nbsp;Following the release of the findings on living wills by the Federal Reserve Board and the Federal Deposit Insurance Corporation, the Forum issued a <a href="https://fsforum.com/news/forum-comments-on-positive-assessment-from-federal-reserve-and-fdic-on-resolution-plan-review">statement</a> highlighting that the agencies found no deficiencies in their review of the Forum member institutions’ resolution plans. The Forum noted that these findings reaffirm that the firms have a strategy in place to be resolved in an orderly way, without cost to taxpayers. The agencies have repeatedly reached the same conclusion during the past decade, further demonstrating the ongoing commitment of the largest U.S. banks to the safety of the financial system.<h2>&nbsp;</h2><h2>Our Two Cents</h2>Research from the ForumThe BankNotes Blog spotlighted <a href="https://fsforum.com/news/looking-at-the-big-picture-on-large-bank-capital-capital-is-at-the-high-end-of-the-optimal-range">research</a> regarding large bank capital and how a systematic and quantitatively rigorous economic analysis shows that Forum members maintain robust capital levels that appropriately support bank safety and financial stability.&nbsp;<h2>Checking the Balance</h2>Members in the newsBank of America&nbsp;<a href="https://newsroom.bankofamerica.com/content/newsroom/press-releases/2022/12/bank-of-america-commits--13-million-to-chicago-area-nonprofits-w.html">announced&nbsp;</a>$13 million in funding to more than 100 Chicago-area nonprofit organizations working to drive economic opportunity for individuals and families in underserved local communities. The bank partnered with nonprofits that are addressing key factors that contribute to economic inequality across the Chicago area, with targeted support to organizations supporting health, jobs, small business, and community development.BNY Mellon <a href="https://www.bnymellon.com/us/en/about-us/newsroom/company-news/bny-mellon-hires-veteran-owned-firms-to-participate-in-a-750-million-dollar-senior-bank-note-issuance-in-honor-of-national-veterans-and-military-families-month.html?cid=CORP_OSM_YD005540_BankNoteSocial_ALLSEG_PUB_NA_TWT_____">collaborated</a> with eight veteran-owned broker-dealers, all founded by military servicemembers, on a $750 million senior bank note issuance, recognizing the important contributions servicemembers provide to the country every day. The announcement is the latest example of BNY Mellon’s dedicated support for diversity and inclusivity in the capital markets—and the company at large.Citi <a href="https://www.citigroup.com/citi/news/2022/221121a.htm">announced</a> that it will donate over $10 million in support of education-focused nonprofit organizations as part of its <a href="https://www.citifx.com/e4e/">2022 e for education campaign</a>, the highest annual amount since the initiative was launched. With this donation, the campaign is set to donate over $66 million in aggregate since its inception in 2013 and has helped nonprofit organizations support over one million young people.Goldman Sachs <a href="https://www.goldmansachs.com/media-relations/press-releases/2022/introducing-datonomy-11-03-2022.html">launched</a> Datonomy, a new classification system for the digital assets market. Designed to provide a consistent, standardized way to help market participants view and analyze the digital assets ecosystem, Datonomy will help create an increased level of transparency into how the market is moving and can be licensed for a variety of uses, such as the review and assessment of portfolio performance and reporting.JPMorgan Chase <a href="https://www.jpmorganchase.com/news-stories/jpmc-commits-7-45-million-to-help-housing-affordability-gap-in-south-florida">announced</a> it will donate more than $7 million to Miami Homes For All and Solar and Energy Loan Fund to help small scale, minority developers and property owners produce and preserve climate-resilient, affordable housing. The announcement is part of JPMorgan Chase’s $<a href="https://www.jpmorganchase.com/news-stories/jpmorgan-chase-commitment-to-closing-the-housing-affordability-gap-for-black-and-latinx-households">400 million, five-year commitment</a> to improve housing affordability and stability for households of color and reflects the firm’s strategy to combat the housing crisis.Morgan Stanley <a href="https://www.morganstanley.com/press-releases/1gt-growth-oriented-private-equity-platform">launched</a> the 1GT growth-oriented private equity platform focused on making investments in companies seeking to mitigate climate change. Part of Morgan Stanley Investment Management’s $200 billion alternative investments business, 1GT is targeting investments in private companies based primarily in North America and Europe whose products or services enable meaningful improvement in their clients’ carbon footprint.State Street <a href="https://newsroom.statestreet.com/press-releases/press-release-details/2022/State-Street-Announces-Inaugural-500-Million-Bond-Issuance-Under-its-Sustainability-Bond-Framework/default.aspx">issued</a> $1 billion of senior unsecured bonds, including an inaugural $500 million bond issued under its Sustainability Bond Framework that enables the issuance of Green, Social, and Sustainability Bonds. The Framework was developed as a key element of State Street’s broader environmental, social and governance strategy and will help channel investment into sustainability-focused projects.In partnership with the National Urban League, Wells Fargo <a href="https://newsroom.wf.com/English/news-releases/news-release-details/2022/National-Urban-League-Partnership-With-Wells-Fargo-Aims-To-Diversify-Home-Appraisal-Industry/default.aspx">announced</a> a $5 million grant to create the Diverse Appraiser Initiative, a new program to increase diversity and reduce barriers to entry in the home appraisal industry. The initiative aims to certify up to 260 diverse appraisers over five years and includes entrepreneurship and small business development components with a focus on creating 130 potential new businesses.

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The Forum File, 2022 Edition #7

Policy Cents

Her Agenda

External Link

Building Generational Wealth Through Homeownership

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<ul><li>Bank of America is the largest private investor in Community Development Financial Institutions (CDFIs) in the United States.&nbsp; The company provides capital to more than 250 CDFIs across all 50 states, which supply affordable, responsible loans and technical assistance to low-income and other underserved clients and communities.&nbsp;Bank of America’s portfolio of loans, deposits and investments to CDFIs exceeds $2 billion. Additionally, as part of its $1 billion commitment to closing the racial wealth gap, the bank has committed $50 million to support MDIs.</li><li>Citi has provided $173 million in capital, administered over $886 million in financing, and committed more than $79 million in philanthropic funding to more than 80 CDFIs across the country since 2015. The bank has also made its ATM network available free of charge to clients of nearly 30 MDIs and CDFIs – providing their customers with convenience and nearly $1 million in savings.</li><li>Goldman Sachs&nbsp;provided $774.5 million to eight different CDFIs between 2016 and 2020.</li><li>JPMorgan Chase&nbsp;has made 64 loans totaling more than $870 million to CDFIs and invested more than $1.4 billion in 49 different CDFIs through the New Markets Tax Credit program since 2015. Additionally, from 2015 to 2019 the firm provided 1,001 grants to 145 CDFIs totaling $194 million and continues to mentor and advise select MDIs and CDFIs to help them achieve their future success.</li><li>Morgan Stanley&nbsp;has provided $3.6 billion in investment in 41 CDFIs and $30.5 million in investment in three MDIs between 2016 and 2020. Additionally, the firm has <a href="https://www.morganstanley.com/press-releases/morgan-stanley-announces--10-million-to-support-minority-deposit">committed</a> $10 million in grants supporting MDIs.</li><li>Wells Fargo&nbsp;has invested $847 million in 305 unique CDFIs through grant and debt capital since 2015. Additionally, the bank has <a href="https://stories.wf.com/wells-fargo-announces-seeking-commit-50-million-capital-minority-depository-institutions/">committed</a> to investing up to $50 million in capital for MDIs.</li></ul>

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Supporting CDFIs and MDIs

We are supporting hundreds of Community Development Financial Institutions (CDFIs) and Minority Depository Institutions (MDIs) by providing over $8.5 billion in capital and financing between 2016 and 2020.

<ul><li>Bank of America&nbsp;in 2020&nbsp;<a href="https://newsroom.bankofamerica.com/press-releases/bank-america-announces-four-year-1-billion-commitment-supporting-economic">committed</a> $1 billion over four years to help local communities address economic and racial inequality. The firm has also <a href="https://newsroom.bankofamerica.com/press-releases/community-development/smithsonian-announces-race-community-and-our-shared-future#:~:text=Bank%20of%20America's%20%2425%20million,economic%20opportunity%20in%20minority%20communities.">committed</a> an additional $25 million to the Smithsonian to fund its Race, Community and Our Shared Future initiative, <a href="https://newsroom.bankofamerica.com/press-releases/corporate-philanthropy/bank-america-expands-support-boys-girls-clubs-america-1">provided</a> a $1 million grant to the Boys &amp; Girls Clubs of America, and made a $22.1 million <a href="https://newsroom.bankofamerica.com/press-releases/corporate-philanthropy/bank-america-expands-support-boys-girls-clubs-america-1">investment</a> in 2020 Neighborhood Builders and Neighborhood Champions in Support of Local Organizations.&nbsp; &nbsp;&nbsp;</li><li>BNY Mellon&nbsp;has <a href="https://www.bnymellon.com/us/en/about-us/newsroom/company-news/bny-mellon-commits-20-million-to-fund-the-future-workforce.html">committed</a> $20 million to community colleges and a select group of local and national organizations to support workforce training programs in traditionally underrepresented minority groups and communities. Additionally, the bank made an initial pledge of $1.5 million to organizations including My Brother’s Keeper, the NAACP Legal Defense and Education Fund, the Southern Poverty Law Center, the National Network for Safe Communities and the Vera Institute of Justice.</li><li>Citi <a href="https://www.citigroup.com/citi/news/2020/200923a.htm">launched</a> more than $1 billion in strategic initiatives in 2020 aimed at closing the racial wealth gap. The bank also <a href="https://www.citigroup.com/citi/news/2020/200117a.htm">launched</a> the $150 million Citi Impact Fund to make equity investments in ‘double bottom line’ private sector companies, with a focus on women and minority owned businesses.</li><li>Goldman Sachs&nbsp;has launched the One Million Black Women <a href="https://www.goldmansachs.com/our-commitments/sustainability/one-million-black-women/index.html">initiative</a>, a $10 billion investment initiative to advance racial equity and economic opportunity by investing in Black women with the goal of impacting the lives of at least 1 million Black women by 2030. It has also <a href="https://www.goldmansachs.com/media-relations/press-releases/current/gs-fund-for-racial-equity.html">created</a> the Goldman Sachs Fund for Racial Equity, which launched with $10 million – building on the more than $200 million the firm has granted over the past decade to organizations serving communities of color – and aims to support organizations addressing racial injustice, structural inequity and economic prosperity.</li><li>JPMorgan Chase&nbsp;in 2020 <a href="https://www.jpmorganchase.com/news-stories/jpmc-commits-30-billion-to-advance-racial-equity">committed</a> $30 billion to advance racial equity over the next five years through growing Black- and Latinx-owned businesses, improving financial health and access to banking in Black and Latinx communities and accelerating investment to build a more diverse and inclusive workforce.</li><li>Morgan Stanley&nbsp;<a href="https://www.morganstanley.com/press-releases/morgan-stanley-announces-10-million-to-support-national-urban-le">announced</a> $10 million in grants to support the National Urban League, aimed at supporting financial literacy, homeowner counseling and workforce development programs. The firm also <a href="https://www.morganstanley.com/press-releases/morgan-stanley-commits--5-million-to-naacp-legal-defense-and-edu">committed</a> $5 million on top of matching employee contributions to the NAACP Legal Defense and Education Fund to support its work in fighting for racial justice.</li><li>State Street&nbsp;in 2020 <a href="https://www.statestreet.com/content/dam/statestreet/documents/New_Commonwealth_Racial_Equity_and_Social_Justice_Fund_Press_Release.pdf">announced</a> a five year, $5 million commitment to the New Commonwealth Racial Equity and Social Justice Fund, which supports Black- and brown-led organizations that are working on economic empowerment, youth civic engagement, healthcare equity and criminal justice reform.</li></ul>

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Combatting Inequality

We are dedicated to combatting inequality through a series of important initiatives. These initiatives support minority owned small businesses and provide funding for community organizations that are dedicated to closing the racial wealth gap.

<ul><li>Bank of America in 2021 provided $6.6 billion to build sustainable communities, creating more than <a href="https://newsroom.bankofamerica.com/content/newsroom/press-releases/2021/02/bank-of-america-community-development-banking-provided-record--5.html">11,600 affordable housing units</a>, including 3,200 units for senior citizens, 3,400 units for formerly homeless, veterans, or those with special needs, and 5,500 certified green units. The bank also tripled its affordable homeownership initiative to $15 billion through 2027, giving homebuyers as much as $10,000 for down payments and as much as $7,500 for closing costs.</li><li>Citi in 2021 established its <a href="https://www.citibank.com/icg/sa/citicommunitycapital/">Affordable Housing Preservation Program</a>, investing more than $200 million, out of a $550 million three- year commitment to affordable housing, in five equity funds co-managed by Black investment managers to preserve multi-family rental housing. In Oregon, Citi provided a $10.0 million construction loan and a $4.7 million permanent loan for the renovation of Webster House, a 48-unit project targeting elderly households experiencing homelessness or at risk of becoming homeless.</li><li>Goldman Sachs promotes affordable housing through its <a href="https://www.goldmansachs.com/what-we-do/asset-management/impact-investing/">Urban Investment Group (UIG)</a>, a domestic, multi-asset class investing and lending business that provides capital to real estate developments and social enterprises working in underserved communities. In 2021, UIG deployed over $3 billion in community development loans in low- and moderate-income communities and created and preserved 4,617 units of affordable housing across the country.</li><li>JPMorgan Chase in 2021 <a href="https://www.jpmorgan.com/commercial-banking/insights/affordable-housing-preservation-two-years-in">announced</a> it had committed more than $13 billion in financing for over 100,000 affordable housing units as part of its Affordable Housing Preservation Program. In 2020, JPMorgan Chase announced its <a href="https://www.jpmorgan.com/commercial-banking/insights/breaking-down-barriers-to-affordable-housing---jpmorgan-chase">commitment</a> to finance 100,000 affordable housing units in underserved communities, originate 40,000 home loans for Black and Latinx households, and help 20,000 Black and Latinx households lower their mortgage payments through refinancing. The bank has also committed to originating over 40,000 home purchase loans and refinancing an additional 20,000 loans in minority neighborhoods.</li><li>Morgan Stanley, along with the National Equity Fund, in 2022 <a href="https://www.connectcre.com/stories/morgan-stanley-nef-invest-250m-in-affordable-housing-program/">committed $250 million</a> to preserve and deliver quality affordable and workforce housing at a national level. In 2021, Morgan Stanley partnered with the Metropolitan Atlanta Rapid Transit Authority (MARTA) and the National Equity Foundation to <a href="https://www.housingfinance.com/finance/partnership-launches-100-million-fund-to-preserve-housing-near-marta-stations_o">launch</a> the Greater Atlanta Transit-Oriented Affordable Housing Preservation Fund to boost MARTA’s affordable housing effort, which supports long-term preservationof affordable housing near MARTA rail stations by incentivizing and providing gap funding for owners of affordable housing.</li><li>State Street is a longtime supporter of <a href="https://www.metrohousingboston.org/about/">Metro Housing | Boston</a>, a Boston nonprofit that works with individuals and families who are homeless or at risk of losing their homes, helping them navigate available services to empower them to move along the continuum from homelessness to housing stability. In 2020, State Street in 2020 invested over $240 million in <a href="https://www.statestreet.com/values/economic-responsibilities.html">affordable housing</a> communities throughout the U.S., through the Low-Income Housing Tax Credit program. Since 2010, State Street has invested over $1.7 billion in affordable housing.</li><li>Wells Fargo in 2022 <a href="https://newsroom.wf.com/English/news-releases/news-release-details/2022/Wells-Fargo-Foundation-Aims-to-Grow-Diverse-Housing-Developers-with-40-Million-Donation/default.aspx">announced</a> Growing Diverse Housing Developers, a $40 million grant initiative focused on expanding the growth and success of real estate developers of color, including Black- and Latino-owned firms, as well as increasing the supply of affordable homes across the country. Wells Fargo also works with NeighborWorks America <a href="https://nl.wfhmconsumerevents.com/">to provide</a> down payment assistance and homebuyer education for low- and moderate-income families. In one initiative, in 2021 the bank committed to invest $5 million to help more than 300 low- and moderate-income residents in Houston with home down payment assistance.</li></ul>

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Commitment to Affordable Housing

Forum members are playing a leading role in promoting affordable housing throughout the country. In 2021 alone, Forum banks created or preserved more than 150,000 affordable housing units.

<ul><li>Recognizing the importance of a banking relationship to help narrow the wealth gap, Forum members were founding lenders in a pilot program with CFE to offer&nbsp;<a href="https://cfefund.org/project/bank-on/">BankOn accounts</a> to people across the country. More than <a href="https://2wvkof1mfraz2etgea1p8kiy-wpengine.netdna-ssl.com/wp-content/uploads/2021/07/CFE-Fund_-2021-Bank-On-100-Accts-Press-Release.pdf">100 lenders</a> big and small now offer BankOn accounts, <a href="https://www.stlouisfed.org/~/media/files/pdfs/community-development/bank-on/bankon_data.pdf?la=en">successfully</a> bringing people into the banking system.</li><li>Forum members have worked with CFE Fund and others to launch Financial Empowerment Centers in cities across the country. These centers offer free financial counseling, helping clients navigate complex financial situations and plan for the future. Additionally, the program supports strategic research projects to enhance the success of financial counseling.&nbsp;<a href="https://cfefund.org/project/financial-empowerment-centers/">Learn more</a>.</li><li>Bank of America, Citi, JPMorgan Chase, and Wells Fargo have long partnered with Cities for Financial Empowerment (CFE) to provide low-cost, low-fee checking accounts to help bring more people into the banking system.</li><li>The Citi Foundation <a href="https://www.prnewswire.com/news-releases/the-citi-foundation-and-cities-for-financial-empowerment-fund-to-increase-summer-job-opportunities-financial-education-and-banking-access-to-an-additional-140-000-young-people-301316128.html">announced</a> an additional $3.66 million in support to the CFE&nbsp;to increase summer job opportunities, financial education, and banking access to an additional 140,000 young people.</li><li>Forum members are working with the OCC on&nbsp;<a href="https://www.occ.treas.gov/topics/consumers-and-communities/minority-outreach/project-reach-fact-sheet.pdf">Project REACh</a>, a program to promote financial inclusion.&nbsp;Led by JPMorgan Chase, banks have worked to find ways to help people without traditional credit histories access credit. The banks have created a tool to import non-traditional data sources, such as deposit account activity, to allow lenders to have greater options to assess creditworthiness.</li><li>The Wells Fargo Foundation <a href="applewebdata://9AC3D0AC-44A3-42B2-AAA0-A73664A505E0/%E2%80%A2%09https:/cfefund.org/cfe-fund-and-wells-fargo-announce-third-cohort-of-bank-on-fellowship/">announced</a> a $1 million grant to CFE to increase the size of the BankOn Fellowship Program, which funds a full-time BankOn coalition leader focused on improving banking access for residents.</li></ul>

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Bringing Those Outside of Banking In

Forum members have long been on the frontlines in the effort to bring unbanked and underbanked Americans into the financial mainstream.

<ul><li>Bank of America&nbsp;has committed to spending nearly $2 billion annually with diverse businesses through its <a href="https://about.bankofamerica.com/en-us/what-guides-us/vendor-management.html#fbid=tlM4qFkwCad">Supplier Diversity program</a>.</li><li>BNY Mellon&nbsp;has established a dedicated <a href="https://www.bnymellon.com/us/en/supply-chain-responsibility-program/supply-chain-responsibility-program-statement.html">Supply Chain Responsibility program</a> to build and maintain a diverse supplier base, as well as host workshops and expos to support diverse vendor development.</li><li>Citi actively seeks diverse suppliers through minority and women business development organizations and participation in various trade show activities while utilizing diverse suppliers and consultants through their <a href="https://www.citigroup.com/citi/suppliers/who.htm">Supplier Diversity program</a>.</li><li>Goldman Sachs&nbsp;has <a href="https://www.goldmansachs.com/our-commitments/sustainability/our-vendor-program/vendor-diversity/">committed</a> to increasing spending with diverse vendors by 50 percent by 2025.</li><li>JPMorgan Chase&nbsp;has set a goal of continually exceeding $1 billion in spending with <a href="https://www.jpmorganchase.com/about/suppliers/supplier-diversity">diverse suppliers</a> each year.</li><li>Morgan Stanley&nbsp;<a href="https://www.morganstanley.com/about-us/supplier-diversity">partners</a> with supplier diversity organizations like the Women’s Business Enterprise National Council and the National Minority Supplier Development Council.</li><li>State Street&nbsp;has committed to increasing its spending with diverse suppliers over the next three years in order to strengthen Black- and Latinx-owned businesses.</li><li>Wells Fargo&nbsp;aims to spend 15 percent of its procurement budget with diverse suppliers through the bank’s <a href="https://www.wellsfargo.com/about/diversity/supplier-diversity/commitment/">Supplier Diversity program</a>.</li></ul>

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Supporting Diverse Suppliers

Our institutions are committing to partner with diverse vendors and suppliers to support minority and women-owned businesses.

We invested nearly $9 billion in Community Development Financial Institutions between 2016 and 2020.

Supporting Historically Underserved Communities

Bloomberg

NYC, Goldman Sachs Launch Effort to Give Struggling Small Businesses a Lift

World Economic Forum

Why Supporting SMEs is Critical for Global Trade Stability and a More Inclusive Economy

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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>

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Lending

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>

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Liquid Capital Markets

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. 

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Our Employees

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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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 & 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 & 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 & 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, Forum Chair

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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 & 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 & Company. She started her career at Goldman Sachs in the Mergers & 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 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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BNY Mellon

Robin Vince is President and Chief Executive Officer of BNY Mellon and a member of its Board of Directors. Previously, he was Vice Chair of BNY Mellon and CEO of Global Market Infrastructure. In that role, he oversaw BNY Mellon’s Clearance and Collateral Management, Treasury Services, Markets and Execution Services and Pershing businesses.

Prior to joining BNY Mellon 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 Mellon 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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JPMorgan Chase & Co.

Jamie Dimon is Chairman of the Board and Chief Executive Officer of JPMorgan Chase & Co., 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

JPMorgan Chase & Co. Chairman And Chief Executive Officer

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Morgan Stanley

Mr. Gorman is Chairman and CEO of Morgan Stanley.

Mr. Gorman became CEO in January 2010 and Chairman in January 2012. He joined the Firm in February 2006 and was named Co-President in December 2007.

Before joining Morgan Stanley, Mr. Gorman held a succession of executive positions at Merrill Lynch. Prior to this, he was a senior partner of McKinsey & Co. and began his career as an attorney in Melbourne, Australia.

Among his civic activities, Mr. Gorman serves as a Director of the Federal Reserve Bank of New York and the Council on Foreign Relations, and is a member of the Board of Overseers of the Columbia Business School, the Monetary Authority of Singapore International Advisory Panel, the Business Council, and the Board of the Institute of International Finance.

He formerly served as President of the Federal Advisory Council to the U.S. Federal Reserve Board, Co-Chairman of the Partnership for New York City, Chairman of the Board of the Securities Industry and Financial Markets Association and Co-Chairman of the Business Committee of the Metropolitan Museum of Art.

Mr. Gorman, who was born in Australia, earned a B.A. and Law degree from the University of Melbourne and an M.B.A. from Columbia University.

James Gorman

Morgan Stanley Chairman And Chief Executive Officer

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