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Dear reader,We’re back by popular demand—and just in time for a busy June in Washington. With longer days and growing policy momentum, there’s plenty to cover. In this issue, we highlight Wells Fargo’s new small business initiative, look at how changes to bank rules could help support the U.S. Treasury market and American economy, and share how Forum members are driving innovation, and community growth nationwide.Thanks for keeping up with us.Kevin Fromer, President and CEO, Financial Services Forum<h2>Penny For Your Thoughts</h2>Kimelyn Harris, head of Small Business Growth Philanthropy for Wells Fargo&nbsp;<h3>What is Wells Fargo’s Open for Business Growth program?</h3>This new $20 million Open for Business Growth program is designed to support the growth potential of small businesses in the “missing middle”– those that are in-between most capital solutions. During the pandemic, Wells Fargo created its Open for Business Fund, a $420 million national small business recovery effort. Through this fund, Wells Fargo collaborated with community organizations to benefit roughly 336,000 small businesses and enable them to keep or maintain 461,000 jobs nationwide. Open for Business Growth builds on that momentum and Wells Fargo’s focus on small business growth.<h3>What do small businesses need to be successful?</h3>Access to capital is the number one need we hear from small businesses. Often these businesses need a little bit more than a microloan but are not ready for traditional financing. Open for Business Growth allows our nonprofit grantees to develop products and services and coaching that embrace growth-stage small businesses so they can reach the next level of success.<h3>How will the Open for Business Growth program be deployed? Which cities?</h3>Our first grant recipient, Allies for Community Business, focuses on growing the construction industry around Chicago and helping businesses that have fluctuating revenue flow, like restaurants and retail. &nbsp;With grant funding, Allies for Community Business is deploying creative capital and flexible financing options that give businesses the leap they need to expand. We’re excited to announce grants in additional markets across the U.S. through end of the year.<h3>Can you explain more what you mean by “missing middle” for small businesses?</h3>Across the country, millions of small businesses serve as the backbone of America’s economy. They provide vital services and goods, as well as jobs for local communities. But there’s a “missing middle” of small businesses ready for expansion but not able to find the flexible capital solutions they need to grow. These small businesses are on the brink of expansion, poised to make an even greater impact in creating jobs, increasing services, and strengthening the economy. They need more than a microloan, but are not yet large enough for traditional financing.<h2>Value Add</h2>Supporting Small Businesses Recovering from the L.A. Wildfires&nbsp;&nbsp;<figure class="image image_resized" style="width:52.97%;"><img src="https://s205.q4cdn.com/885744627/files/doc_multimedia/2025/5/1009701913/HOPE_Inside_for_Small_Business-NR_Image810x450.jpg" alt="Wells Fargo Newsroom - Wells Fargo and Operation HOPE Introduce Free Financial Coaching to Small Businesses"></figure>Wells Fargo is working across the bank to support small business growth. Through Beyond Open for Business initiatives, Wells Fargo is expanding support services to include resources, knowledge and networking opportunities for businesses owners, which is also imperative to their growth.&nbsp; In the Greater Los Angeles area, many local businesses are trying to recover from the devastating wildfires. There Wells Fargo is collaborating with Operation HOPE to extend financial coaching services to small business owners at several Wells&nbsp;Fargo branches as part of the Project Restore HOPE Los Angeles initiative. The five-year effort helps those affected by wildfires with immediate and long-term financial recovery by helping them with FEMA applications, SBA loans, insurance claims, working with creditors, building a recovery budget, and much more. Additionally, Wells Fargo donated $2 million to local nonprofits to support ongoing relief efforts for small businesses and individuals.&nbsp;&nbsp;&nbsp;Wells Fargo believes philanthropy can be a catalyst for lasting impact and collaboration as key to moving the needle, listening to what communities need and co-designing with them. Small businesses are an important path to economic opportunity and wealth-building. Our country needs small businesses as a driver of the U.S economy.<h2>Capital Gains</h2>What we’re doing in WashingtonThe Forum continues to advocate for common sense policies that allow our members to best serve their customers and the U.S. economy. Recently, Forum President and CEO Kevin Fromer <a href="https://fsforum.com/news/forum-applauds-house-committee-passage-of-measures-to-improve-bank-supervision">issued</a> a statement after the House Financial Services Committee voted to advance measures to improve bank supervision. “The FIRM Act, the FAIR Exams Act, and the HUMPS Act represent important steps toward a supervisory system that is consistent and transparent,” Fromer said.Additionally, the Forum, along with fellow trade associations, <a href="https://fsforum.com/news/financial-associations-urge-federal-reserve-to-address-potential-uncertainty-caused-by-stress-capital-buffer-proposal-timing">urged</a> the Federal Reserve to take prompt, interim steps to clarify the 2025 stress test cycle to avoid unnecessary uncertainty.Finally, the Forum <a href="https://fsforum.com/news/forum-applauds-senate-committee-approval-of-governor-bowman-for-vice-chair-for-supervision">applauded</a> the Senate Banking Committee’s vote to advance Federal Reserve Governor Michelle Bowman for Federal Reserve Vice Chair for Supervision and urged swift Senate confirmation. “This role is critical to implementing appropriate regulation and effective supervision that promotes economic growth,” Fromer said.<h2>&nbsp;Our Two Cents</h2>Research from the ForumThe following chart shows how changing the Supplementary Leverage Ratio (SLR) could help large banks buy and hold more U.S. Treasuries. The chart compares the current capacity of the Forum members to hold Treasuries and the additional capacity that would be available under a more flexible standard.<figure class="image image_resized" style="width:62.29%;"><img src="https://fsforum.com/a/media/ff-chart-6.5.png"></figure>In the latest edition of the BankNotes Blog, Forum Chief Economist Sean Campbell <a href="https://fsforum.com/news/correcting-the-record-on-leverage-reform-leverage-requirements-are-already-backfiring">addresses</a> key misrepresentations about leverage capital requirements and discusses why the economy needs change. "Outmoded and arbitrary leverage capital regulations have been backfiring on the U.S. economy for years and are in serious need of reform," said Dr. Campbell.<h2>Checking the Balance</h2>Members in the newsBank of America <a href="https://newsroom.bankofamerica.com/content/newsroom/press-releases/2025/05/bofa-to-open-150-financial-centers-by-2027--investing-over--5-bi.html">announced</a> plans to open over 150 financial centers across 60 markets by the end of 2027, expanding access to banking services nationwide.BNY <a href="https://www.bny.com/corporate/global/en/about-us/newsroom/press-release/bny-expands-digital-asset-platform-with-launch-of-innovative-on-chain-offering.html">expanded</a> its digital asset platform offering&nbsp; with a new data insights product that securely and efficiently deliver both on- and off-chain data across blockchain networks.Citi <a href="https://www.citigroup.com/global/news/perspective/2025/20-years-global-community-day">celebrated</a> the 20th anniversary of Global Community Day, its annual tradition of global volunteerism and community impact.In April, Goldman Sachs 10,000 Small Businesses&nbsp;announced its 1,000th <a href="https://www.goldmansachs.com/pressroom/press-releases/2025/10ksb-announces-thousandth-graduate-in-salt-lake-city-and-launches-new-program-across-utah">graduate&nbsp;</a>in Salt Lake City, as the firm celebrates 25 years in the city. Goldman Sachs 10,000 Small Businesses also opened applications across Utah as part of its $100 million Investment in Rural Communities, an initiative that launched in 2023 and equips rural entrepreneurs with results-oriented training to help grow their businesses and expand access to capital and to personalized support services.&nbsp;JPMorganChase <a href="https://www.jpmorganchase.com/newsroom/press-releases/2025/workplace-public-benefits-commitment-LMI-consumers">committed</a> $14.5 million in philanthropic funding to improve access to&nbsp;workplace and public benefits&nbsp;for low- to moderate-income individuals.Morgan Stanley&nbsp;<a href="https://www.morganstanley.com/articles/supporting-childrens-mental-health?cid=SM_CORP_TWITTER_MorganStanley_20250408&amp;linkId=793617378">celebrated</a>&nbsp;the 5th anniversary of its&nbsp;Alliance for Children’s Mental Health, reaffirming its $50 million commitment to&nbsp;youth mental health solutions by making&nbsp;multi-year grants to nonprofit members and expanding its&nbsp;<a href="https://www.morganstanley.com/press-releases/children-s-mental-health-innovation-awards-2025">Innovation Awards</a>&nbsp;program to include younger leaders.State Street <a href="https://www.statestreet.com/us/en/asset-manager/insights/market-outlook-2025-second-quarter">highlighted</a> key insights into evolving market dynamics and shared its outlook for the second quarter of 2025.&nbsp;&nbsp;Wells Fargo <a href="https://newsroom.wf.com/news-releases/news-details/2025/Wells-Fargo-and-Operation-HOPE-Introduce-Free-Financial-Coaching-to-Small-Businesses/default.aspx">partnered</a> with Operation HOPE to expand access to financial education workshops and personalized coaching for small business owners.&nbsp;

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The Forum File, 2025 Edition #1

Contact: Laura Peavey&nbsp;&nbsp;(202) 457-8770&nbsp;lpeavey@fsforum.comFinancial Services Forum Congratulates Michelle Bowman on her Confirmation as Fed Vice Chair for Supervision"Sound banking regulation and supervision are crucial for maintaining a safe and sound financial system."Washington, D.C. – Financial Services Forum President and CEO Kevin Fromer issued the following statement today after the Senate confirmed Federal Reserve Governor Michelle Bowman as the Federal Reserve Board’s Vice Chair for Supervision:“The Forum congratulates Governor Bowman on her confirmation as Vice Chair for Supervision and commends President Trump, Chairman Scott, and the Senate for their action to fill this important position. Sound banking regulation and supervision are crucial for maintaining a safe and robust financial system. As Vice Chair for Supervision, Governor Bowman will be instrumental in shaping policies and practices that affect the ability of banks to support our economy and promote financial stability. America’s leading banks look forward to working with Vice Chair Bowman to advance effective regulatory and supervisory policies that benefit the broader U.S. economy.”###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>

Financial Services Forum Congratulates Michelle Bowman on her Confirmation as Fed Vice Chair for Supervision

Contact: Laura Peavey&nbsp;&nbsp;(202) 457-8770&nbsp;lpeavey@fsforum.comNew Report Highlights Growing Burden of U.S. GSIB Surcharge on American EconomyWashington D.C. – The Financial Services Forum today released a research paper analyzing the growing capital surcharges imposed on U.S. global systemically important banks (GSIBs) and the broader implications for the financial system and economy.A GSIB score is intended to measure how much systemic risk a bank poses to the financial system. The higher the score, the more capital the bank must maintain. While capital is intended to absorb losses, the paper highlights how unnecessarily high capital requirements have been shown to limit U.S. banks’ ability to lend and to compete with their international peers who face lower requirements—ultimately harming American consumers and businesses.Key Findings:<ol><li>Rising GSIB Surcharges: The analysis shows that capital surcharges for U.S. GSIBs have continued to increase, largely driven by growth in safe assets such as bank reserves and U.S. Treasuries.</li><li>Uneven Global Standards: Unlike their international counterparts, U.S. GSIB scores are not adjusted for overall financial system growth, resulting in disproportionately higher scores and surcharges for U.S. banks.</li><li>Economic Implications: Without reform, GSIB scores and surcharges are expected to continue rising, potentially constraining bank lending and posing broader economic challenges.</li></ol>The paper’s findings call for a reassessment of the GSIB scoring methodology to ensure it accurately reflects systemic risk and promotes a level playing field for U.S. financial institutions and the customers they serve.Read the full paper <a href="https://fsforum.com/a/media/gsib_paper_6.2.25.pdf">here </a>and an accompanying blog <a href="https://fsforum.com/news/to-infinity-and-beyond-the-supply-of-safe-assets-and-gsib-capital-surcharges">here</a>.###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>

New Report Highlights Growing Burden of U.S. GSIB Surcharge on American Economy

<h3>Introduction</h3>Twelve years ago, international regulators imposed a new capital <a href="https://www.bis.org/publ/bcbs255.pdf">requirement</a> on the world’s largest banks, a group of roughly 30 institutions termed Global Systemically Important Banks, or GSIBs.&nbsp; The capital charge, stated as a percentage of assets, was justified by the concern that distress or failure of a GSIB would cause undue disruption to financial stability and the economy.&nbsp; The amount of the capital requirement is based on a scoring method that serves as a proxy for systemic risk.&nbsp; The Federal Reserve adopted a more stringent, U.S. version of this <a href="https://www.federalreserve.gov/newsevents/pressreleases/bcreg20150720a.htm">requirement</a> a decade ago.In the U.S., eight banks, the Financial Services Forum members, are subject to the GSIB surcharge.&nbsp; A key and longstanding concern with the U.S. GSIB surcharge is that it is measured in nominal terms without adjusting for the overall size of the banking system, financial system, or economy.&nbsp; As a result, as the economy and financial system grow, so too do GSIB surcharges.&nbsp; Since 2016, the average U.S. GSIB surcharge has increased by 0.4 percentage points, which translates to roughly an additional $50 billion in required capital.&nbsp; In this blog we review the research findings from our recent <a href="https://fsforum.com/a/media/gsib_paper_6.2.25.pdf">paper </a>that documents the source of growth in GSIB surcharges since 2016.&nbsp; We find that all growth in aggregate GSIB surcharges can be attributed to growth in the financial system as measured by growth in the supply of safe assets - bank reserves and U.S. Treasuries.&nbsp; Further, we project that absent any change in how the GSIB surcharge is calculated, GSIB surcharges will continue their steady upward trajectory over the next decade.&nbsp; Rising capital requirements that are not driven by actual risks but by the growth in safe and liquid assets will unnecessarily raise the cost of bank borrowing, creating an unnecessary headwind for the economy.&nbsp;<h3>Diagnosing The Problem: Which One of These Is Not Like the Others?</h3>The GSIB surcharge is determined by a regulator-defined measure of systemic risk – the GSIB score – that depends on a lengthy list of bank characteristics such as the size of a bank’s balance sheet and the amount of derivatives and trading activity conducted by a bank.&nbsp;The GSIB score is calculated differently in the U.S. than in other countries.&nbsp; In all countries except the U.S., a bank’s GSIB score is deflated annually by the total size of the global banking system.&nbsp; As a result, if all banks across the globe were to increase their balance sheet by, say 10 percent, the GSIB score for all non-U.S. banks would remain unchanged.&nbsp;This annual deflation is a simple and sensible policy that is akin to deflating the cost of gasoline by the level of inflation to accurately measure the real, inflation-adjusted price of gas over time.&nbsp; If gas prices rise three percent when inflation also rises three percent, nobody claims that we are having another OPEC crisis.&nbsp; Similarly, an increase in the size and scale of some banks matching the broad growth throughout the banking sector and economy does not signal an increase in “systemic risk.”&nbsp; The U.S. GSIB score, however, does not abide by this simple and sensible policy.&nbsp; The U.S. GSIB surcharge rule does not index GSIB scores for the growth of the economy and financial system. In Figure 1, we show a plot of the average score for a U.S. GSIB under our rules and the score that results from applying the rules for non-U.S. GSIBs, from 2016 through 2023.&nbsp; Each score is indexed to 100 in 2016 to ease comparison.<figure class="image image_resized" style="width:79.45%;"><img src="https://fsforum.com/a/media/6.2.25-blog.png"><figcaption>Source: <a href="https://www.bis.org/bcbs/gsib/index.htm">BCBS GSIB Dashboard</a>;&nbsp; FR Y-15</figcaption></figure>As shown in the figure, while the average U.S. GSIB score has steadily increased, especially since 2019, the non-U.S. score has actually declined.&nbsp; The divergence between the two scores is driven by the fact that the non-U.S. score is annually deflated for growth in the financial system while the U.S. score is not.&nbsp;&nbsp;&nbsp; &nbsp;&nbsp;To be clear, as banks grow with the overall economy the dollar amount of capital they are required to maintain rises, but the capital requirement, stated as a percentage of assets, is generally invariant to a bank’s size.&nbsp; Indeed, if this were not the case, sooner or later every bank would have a capital requirement exceeding 100 percent.<h3>The Upside Down: Increasing the Supply of Safe Assets and U.S. GSIB Scores</h3>We have just shown that under global GSIB rules, the scores for U.S. banks would have declined.&nbsp; Instead, our rules have caused U.S. GSIB scores – and capital requirements – to increase significantly.&nbsp; This increase results from the fact that the U.S. regulator has not deflated GSIB scores for growth in the economy and financial system.&nbsp; But an important question remains, what exactly is driving the increase in the economy and financial system that is leading to higher U.S. GSIB scores and surcharges?In our research paper we relate the increase in the size of the financial and banking system to the increase in the supply of safe assets – bank reserves and U.S. Treasuries.&nbsp; Both bank reserves and U.S. Treasury securities are low-risk, liquid assets that support a stable financial system.&nbsp; In Figure 2, we show how the supply of safe assets has evolved since 2016.&nbsp; The figure also presents projections for the supply of safe assets over the next decade that are taken directly from official government projections provided by the Congressional Budget Office (CBO) and the Federal Reserve Bank of New York (FRBNY).<figure class="image image_resized" style="width:98.09%;"><img src="https://fsforum.com/a/media/6.2.25-blog-figure-2.png"><figcaption>Source: FRB Reserves of Depository Institutions; U.S. Department of the Treasury: Federal Debt Held by the Public; FRBNY <a href="https://www.newyorkfed.org/markets/annual_reports.html">Annual Report on Open Market Operations</a>; CBO <a href="https://www.cbo.gov/publication/60870">The Budget and Economic Outlook: 2025 to 2035</a></figcaption></figure>As seen in the figure, both bank reserves and outstanding U.S Treasuries expanded greatly at the onset of the COVID pandemic and has remained elevated since that time.&nbsp; In the case of bank reserves (left axis), the Federal Reserve nearly doubled the level of bank reserves in a single quarter.&nbsp; In the case of U.S. Treasuries (right axis), outstanding U.S. Treasuries expanded by over $3 trillion in a single quarter following the outbreak of COVID.&nbsp; Further still, the rate of U.S. Treasury issuance post-COVID has doubled and the CBO projects that this heightened rate of issuance will persist for the next decade.Increasing the supply of safe assets mechanically increases U.S. GSIB scores because these scores are stated in nominal terms.&nbsp; As the Federal Reserve increases the supply of bank reserves, banks must absorb the additional reserve supply.&nbsp; Likewise, as <a href="https://www.newyorkfed.org/markets/primarydealers">primary dealers</a> of U.S. Treasuries, as the U.S. government increases its issuance of Treasury securities, large banks must absorb some portion of the increased supply.&nbsp; In addition, the supply of safe assets in the economy influences the overall amount of financial activity that naturally increases the nominal amount of activity in the banking sector.&nbsp; At the same time, it is important to underscore that these are nominal amounts that reflect the nominal size of the overall banking system and not any particular bank.&nbsp; The observed increase in U.S. GSIB scores simply reflects a larger overall financial system rather than any increase in systemic risk.&nbsp; Quite paradoxically, increasing the supply of safe assets increases financial system liquidity and stability, but this increase is mechanically recorded by regulators as an increase in “systemic risk.”<h3>Oh the Places We’ll Go……?</h3>Using the empirical link between the supply of safe assets and U.S. GSIB scores that we document in our research paper, we can answer two important questions: 1) what would have happened to U.S. GSIB scores and surcharges had the massive growth in safe assets that began with the onset of COVID never occurred? and 2) where do we expect U.S. GSIB scores and surcharges to go over the next decade given the projected path of safe asset supply?Both of these questions are addressed in Figure 3.&nbsp; In the figure we show: 1) the actual path for U.S. GSIB scores (black line) and surcharges (grey shaded area), 2) the counterfactual U.S. GSIB score (blue line) and surcharge (blue shaded area) that we estimate would have occurred absent the growth in safe assets following 2019, 3) the projected U.S. GSIB score (purple dotted line) and surcharge (purple shaded area) that we estimate will occur over the next decade given CBO and FRBNY projections for the future supply of safe assets.<figure class="image image_resized" style="width:96.02%;"><img src="https://fsforum.com/a/media/6.2.25-blog-figure-3.png"><figcaption>Source: FR Y-15; FRB Reserves of Depository Institutions; U.S. Department of the Treasury: Federal Debt Held by the Public; FRBNY <a href="https://www.newyorkfed.org/markets/annual_reports.html">Annual Report on Open Market Operations</a>; CBO <a href="https://www.cbo.gov/publication/60870">The Budget and Economic Outlook: 2025 to 2035</a></figcaption></figure>The counterfactual results (blue line and shaded area), which are produced using our model, show that without the growth in the supply of safe assets that was largely brought on by the pandemic, the average U.S. GSIB score and surcharge would have remained effectively unchanged over the 2016-2024 period.&nbsp; Accordingly, all growth in GSIB scores and surcharges that have been observed since 2020 has been driven by growth in the supply of safe assets and the overall financial system.&nbsp; This result is striking.&nbsp; To the extent that any other factors beyond nominal growth in the financial system influence GSIB scores, none of those factors have played any role in the observed and sustained growth in GSIB scores and surcharges since 2016.Further, Figure 3 also shows that past is prologue in the case of GSIB surcharges.&nbsp; Our estimates imply that over the next 10 years, without any change to the GSIB surcharge rule, average GSIB scores will increase by another 100 points and the average surcharge will increase by another 0.5 percentage points.&nbsp; And once again, all of this projected growth is being driven by projected growth in the nominal size of the supply of government debt rather than any increase in systemic risk.&nbsp; Ironically, increasing the supply of safe and liquid assets is leading to higher surcharges that are erroneously linked to “systemic risk.”This projection is highly concerning.&nbsp; <a href="https://papers.ssrn.com/sol3/papers.cfm?abstract_id=3676674">Research</a> has shown that GSIB banks reduce their lending in response to increased GSIB surcharges.&nbsp; Accordingly, a continued and sustained increase in GSIB scores and surcharges will only reduce support for the economy.&nbsp; This development would be unwelcome both because it is bad for the economy and because it would be driven by basic, underlying economic and financial growth that is wholly unrelated to any notion of systemic risk.<h3>Conclusion</h3>Since 2015, the Federal Reserve has overseen the implementation of the GSIB capital surcharge in concert with other global regulators.&nbsp; Unlike the rest of the world, however, the Federal Reserve has adopted an approach to systemic risk measurement that ignores underlying growth in the banking system and the broader economy.&nbsp; This deviation has created a widening rift between the U.S. and non-U.S. surcharge methodology that clearly disadvantages U.S. banks and their customers relative to their foreign peers and harms the U.S. economy.&nbsp; Further, left unabated, the troubling trend that has been observed since 2016 will only continue and exact an ever-rising toll on the U.S. economy.&nbsp; The Federal Reserve should act swiftly and decisively to arrest this perpetual growth in large bank capital requirements that is divorced from any sensible notion of systemic risk.&nbsp;&nbsp;&nbsp;&nbsp; &nbsp;

To Infinity and Beyond? The Supply of Safe Assets and GSIB Capital Surcharges 

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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

Capital and the U.S. Economy

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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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