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Sean Campbell

Chief Economist, Head of Policy Research

In a recent op-ed, Sheila Bair recited a litany of age-old canards about leverage requirements and leverage reform that are as untrue as they are outdated.&nbsp; Below, we address the key misrepresentations that have been made about leverage requirements, risk-blind capital requirements that compare a bank’s equity capital to a measure of its total assets without regard to their riskiness, and discuss why the economy needs leverage reform in the near term.The Facts:<ol><li>Risk-based capital requirements did not cause the financial crisis.&nbsp; The op-ed argues that an overreliance on risk-based capital requirements caused the 2008 financial crisis.&nbsp; According to this worldview, the financial crisis could have been largely averted if only regulators had relied on leverage capital rather than risk-based requirements.&nbsp; This claim does not comport with the basic fact that U.S. banks were subject to a leverage ratio for years before and during the financial crisis.&nbsp; Additionally, and importantly, economic scholars such as Former Federal Reserve Chairman Ben Bernanke who have painstakingly studied the financial crisis have <a href="https://www.brookings.edu/wp-content/uploads/2018/09/Bernanke_final-draft.pdf">shown </a>that the proximate cause was a run in the non-bank sector that was tied to the non-bank funding of mortgages.&nbsp; Importantly, Bear Stearns, Lehman Brothers, Countrywide Mortgage, Fannie Mae, Freddie Mac and the money market mutual fund industry – all non-banks – failed and took a heavy toll on the economy long before a single bank failure occurred.</li><li>Risk-based capital requirements are not “gamed” by banks.&nbsp; The op-ed asserts that a key motivation for simplistic, risk-blind capital requirements is that they are “simple and transparent” and therefore can’t be “gamed” by the banks.&nbsp; This view of risk-based capital requirements has been outmoded by the very significant capital reforms that were enacted post-2008.&nbsp; Specifically, under Basel III, large banks are subject to standardized risk-based capital requirements that assign regulator-specified risk weights to various asset types that are defined and classified by regulators.&nbsp; Further, the stress tests to which all large banks are subject are unilaterally determined by regulators without any bank input.&nbsp; Current risk-based requirements are determined by regulators and are not “gamed” by the banks.</li><li>The leverage ratio is not “neutral” to capital allocation.&nbsp; The op-ed asserts that leverage ratios are “neutral” to capital allocation.&nbsp; This statement is incorrect.&nbsp; Leverage requirements mandate that every asset be funded with the same amount of equity capital.&nbsp; Low-risk assets, such as U.S. Treasuries and bank reserves, provide correspondingly low levels of financial renumeration.&nbsp; But the total cost of funding any bank asset is determined by the amount of equity that is required to fund the asset.&nbsp; Requiring low-risk and low-yielding assets to be funded with the same amount of equity capital as higher yielding assets disincentivizes banks from putting lower yielding assets on their balance sheet.&nbsp; As long as leverage ratios assign the same marginal capital cost to assets with both low and high levels of risk, lower-risk assets will face a steep disadvantage. &nbsp;&nbsp;&nbsp; &nbsp;</li><li>A binding leverage ratio is not evidence that risk-based capital requirements are too low.&nbsp; From a fundamental risk perspective, leverage capital requirements are completely arbitrary.&nbsp; Imagine a different, completely arbitrary, requirement that determines a bank’s capital requirement in terms of the number of letters in its name stated as a percentage.&nbsp; Under this rule, ACME Bank would have a capital requirement of eight percent.&nbsp; If we found that the risk-based capital requirements for ACME Bank were lower than eight percent, would we conclude that the risk-based requirements were too low?&nbsp; Surely not.&nbsp; A capital requirement with no basis in risk cannot, by design, be used to measure the adequacy of a risk-based system.&nbsp; This statement is as true for leverage-based capital requirements as it is for “name-based” capital requirements.&nbsp; Further, large U.S. banks have tripled their capital levels since the financial crisis and have also increased their capital by roughly 20 percent since 2020.&nbsp; Any assertion that a binding leverage ratio points to insufficient risk-based capital requirements is both conceptually flawed and oblivious to the basic facts on large bank capital levels.</li><li>Lowering the cost of issuing Treasuries does not “re-direct capital away from the private sector and into public coffers.”&nbsp; This statement in the op-ed ignores the fact that the borrowing cost for U.S. Treasuries sets the “base rate” that directly impacts the cost of borrowing for every other type of credit.&nbsp; The borrowing cost for auto loans, student loans, home mortgages, business loans and every other form of credit is directly tied to the “risk-free rate” that is required on U.S. Treasuries.&nbsp; Accordingly, improving the market for U.S. Treasuries is a two-fer: it reduces the cost of the U.S. taxpayers’ debt burden and it helps reduce the cost of borrowing for every other form of credit used by businesses and households.&nbsp;&nbsp;</li></ol>Leverage-based capital requirements are fundamentally flawed in a way that disadvantages low-risk assets, distorts capital allocation, and impedes the efficient flow of credit in the U.S. economy.&nbsp; In addition, the U.S. economy and financial system have significantly evolved since the 2008 financial crisis, rendering leverage capital requirements increasingly outdated.&nbsp; Outmoded and arbitrary leverage capital regulations have been backfiring on the U.S. economy for years and are in serious need of reform.&nbsp; Recent commitments by regulators and other officials to reform leverage requirements is a welcome development that we should all embrace to improve our banking system and the economy.&nbsp; &nbsp;&nbsp;&nbsp;&nbsp;&nbsp; &nbsp; &nbsp;&nbsp;&nbsp;&nbsp; &nbsp;&nbsp;&nbsp;&nbsp;&nbsp;&nbsp;&nbsp;&nbsp;&nbsp;

BankNotes Blog

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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

Correcting the Record on Leverage Reform: Leverage Requirements are Already Backfiring

<h3>Introduction</h3>Nearly four years ago, the Federal Reserve <a href="https://www.federalreserve.gov/newsevents/pressreleases/bcreg20210319a.htm">committed</a> to reconsider the supplementary leverage ratio (SLR) in light of the massive, COVID-driven expansion of the Federal Reserve’s balance sheet.&nbsp; Today, the Federal Reserve’s balance sheet still stands at nearly double its pre-expansion level, but no action has been taken to reform the SLR.&nbsp; Accordingly, there is an urgent need to reconsider the SLR in short order.&nbsp; The current level of the Federal Reserve’s balance sheet, coupled with the existing SLR regulation, results in an unnecessarily binding, risk-blind, capital constraint that is having significant deleterious impacts on financial markets and the economy. &nbsp;In the remainder of this post, we discuss the problems created by risk-blind leverage requirements that have been identified through rigorous academic research.<h3>The Backdrop</h3>The SLR was introduced as a capital requirement for large banks in 2018.&nbsp; The SLR is a risk-blind capital requirement that mandates all large banks to maintain five percent capital against all bank assets irrespective of their risk.&nbsp; Importantly, low-yielding and default-free U.S. Treasury securities and bank reserves issued by the Federal Reserve, the most liquid and risk-free asset in the world economy, must be backed by five percent capital.&nbsp; At the same time, higher-yielding assets such as corporate loans or corporate bonds also require five percent capital under the SLR.&nbsp; In a world in which all assets have the same capital cost, there is a clear and unavoidable incentive to hold higher-yielding assets (corporate loans) than lower-yielding ones (U.S. Treasuries).Back in 2018, the size of the Federal Reserve’s balance sheet was roughly $4 trillion.&nbsp; Today, the Federal Reserve’s balance sheet stands at $6.8 trillion.&nbsp; The additional $2.8 trillion in Federal Reserve assets are largely financed by issuing bank reserves.&nbsp; In the aggregate, banks must hold all of the bank reserves issued by the Federal Reserve.&nbsp; Accordingly, when the Federal Reserve increases its balance sheet it necessarily increases the amount of risk-free assets held by banks and these assets are subject to the 5 percent capital requirement of the SLR.Now that the Federal Reserve is so much larger, more banks are adversely impacted by the SLR because they are required to maintain additional capital on all the additional, risk-free, bank reserves.&nbsp; As the amount of capital required by the SLR has risen, the incentives to pull back on low-risk assets such as U.S. Treasury securities have concomitantly increased.Finally, it is important to fully appreciate how the financial system has changed since 2018.&nbsp; Table 1 below, depicts: 1) the level of the Federal Reserve’s balance sheet, 2) the amount of U.S. Treasury debt outstanding, and 3) the annual interest cost of government debt.<figure class="image"><img src="https://fsforum.com/a/media/3.10.25.png"></figure>As shown in Table 1, while the Federal Reserve has expanded its balance sheet, we have seen a nearly identical expansion in debt issued by the federal government as both have increased by roughly 65 percent.&nbsp; Moreover, the amount of money the government is spending to service its debt has grown by much more, 83 percent, owing to both an increase in outstanding debt and the general increase in interest rates that has occurred recently.&nbsp;Indeed, for the first time since records have been kept, the federal government is now spending more on interest payments than on national defense.&nbsp; What’s more, current projections of federal spending suggest that this gap will only widen in the future and that the nation’s interest bill will only become more pressing.&nbsp; As Table 1 makes clear, the financial system in 2025 looks completely different from the one we knew in 2018 when the SLR was introduced.With this backdrop in mind, it is essential that the U.S. government – including the Federal Reserve – do everything in its power to manage the federal debt, contribute to a well-functioning U.S. Treasury market, and minimize the cost of servicing our national debt.&nbsp; Unfortunately, the current stance of the SLR is antithetical to all these goals.&nbsp;&nbsp;&nbsp;<h3>What Does Research Say About Risk-Blind Leverage Requirements and the U.S. Treasury Market?</h3>We have asserted that leverage requirements are impairing the market for U.S. Treasuries and artificially increasing the cost of government debt.&nbsp; What exactly is the basis for these claims?&nbsp; The best way to assess these claims is to simply look at data-based economic research that has studied the impact of the SLR on U.S. Treasuries and financial markets.&nbsp; Luckily, this is a broad and active area of research.&nbsp; Below, we highlight three relatively recent contributions:<ul><li>A 2024 research <a href="https://www.bostonfed.org/publications/research-department-working-paper/2024/the-effect-of-primary-dealer-constraints-on-intermediation-in-the-treasury-market.aspx">paper</a> by economists at the Federal Reserve Bank of Boston found that the SLR had significant negative impacts on the ability of large dealer banks to intermediate the U.S. Treasury market.&nbsp; Specifically, they found that in response to a more restrictive SLR, dealers reduced their Treasury holdings, leading to a reduction in trading, an increase in the cost of buying and selling U.S. Treasuries, and a weaker response to Treasury auctions.&nbsp;</li><li>A 2022 research <a href="https://papers.ssrn.com/sol3/papers.cfm?abstract_id=4175429">paper</a> by economists at the Federal Reserve Board found that banks respond to balance sheet shocks by reducing their exposure to U.S. Treasuries, particularly through reductions in repo activity. Importantly, the paper distinguishes the SLR’s impact from other regulatory requirements, such as risk-based capital and liquidity coverage ratio requirements, finding that the SLR uniquely constrains a bank’s ability to intermediate the Treasury market. &nbsp;&nbsp;&nbsp;&nbsp;&nbsp;&nbsp;&nbsp;&nbsp;</li><li>A 2023 research <a href="https://www.newyorkfed.org/medialibrary/media/research/staff_reports/sr1070.pdf?sc_lang=en">paper</a> by economists at the Federal Reserve Bank of New York and others found that when U.S. Treasury dealers face capacity constraints, such as occurs from an increasingly binding SLR, the liquidity of the U.S. Treasury market worsens.&nbsp; In particular, as regulatory constraints become more binding, Treasury markets become more volatile and trading in the U.S. Treasury market becomes more costly.&nbsp;&nbsp;&nbsp;</li></ul>The research above makes clear that the SLR is imposing well-documented and significant costs on U.S. Treasury markets and the broader economy.&nbsp; Indeed, the U.S. Treasury market underpins essentially every other financial asset in the world.&nbsp; Accordingly, problems in the U.S. Treasury market necessarily migrate broadly throughout the rest of the financial system.&nbsp; In particular, any increase in U.S. Treasury yields or other strains will immediately spill over into the market for home mortgages, auto loans, business loans and essentially any other financial product used by households and businesses.&nbsp; For all these reasons, the Federal Reserve should take immediate action to reconsider risk-blind leverage requirements to address clearly documented problems in the U.S. Treasury market.Each of the papers above is notable because they are authored by staff of the Federal Reserve system.&nbsp; One might reasonably wonder why so much of this research emanates from within the system.&nbsp; The answer lies in the fact that each of the research papers uses confidential bank data that only the Federal Reserve can access.&nbsp; There is indeed a deep irony that only the Federal Reserve system is truly able to fully assess the implications of leverage constraints on Treasury markets, yet the Federal Reserve has so far failed to act on the findings of its own researchers.<h3>But Wait…There’s More</h3>Much of the research literature and discussion of leverage requirements revolves around the SLR.&nbsp; Lurking in the shadows lies yet another, often hidden, leverage requirement - the Tier 1 leverage requirement.&nbsp; The Tier 1 leverage requirement (T1L) is the precursor to the SLR; it was in effect for decades before the SLR was introduced and is still in effect today.&nbsp; The T1L requirement is essentially the classic, historical leverage ratio that has been used for over 100 years and was arguably a relevant capital metric 100 years ago – capital divided by total assets.&nbsp; The SLR is “supplementary” in the sense that the SLR includes certain off-balance sheet exposures like derivatives and loan commitments that are not recorded in total assets due to technical accounting rules.&nbsp;One might reasonably ask why the T1L requirement was not “de-commissioned” following the introduction of the SLR.&nbsp; The basic answer simply amounts to the fact that bureaucracies are good at creating new rules and bad at eliminating old, outmoded, and unnecessary rules.&nbsp; Dealing with the SLR without dealing with T1L would be a mistake.&nbsp; Modifying the SLR without dealing with T1L would simply amount to replacing the SLR with T1L as the new risk-blind leverage requirement and we would be back to square one all over again.&nbsp; Accordingly, it is important that T1L be addressed alongside the SLR.<h3>Conclusion</h3>Sample evidence and research, often conducted by Federal Reserve system staff, clearly show that risk-blind leverage requirements have been impairing the market for U.S. Treasuries for some time.&nbsp; The problems in the U.S. Treasury market are all the more pressing due to the steep rise in government interest payments and forecasts for an increase in the amount of government borrowing.&nbsp; The Federal Reserve, and other regulators and policymakers, should act swiftly to address the deleterious consequences of risk-blind leverage requirements on the economy.

Promises Made, Promises Kept? The Urgency of Leverage Ratio Reform

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Emma Tong

Research Associate, Policy Research

Companies across the country rely on banks to provide credit that supports their investment, success, and ultimately the growth of our economy.&nbsp; Whether it be a midwestern manufacturer investing in new equipment, a hospital adding a new operating facility to improve care, or an accounting firm purchasing a new building to support its growing employee base, companies of all stripes rely on bank lending to finance the investments that they need to support their growth as well as the customers and communities that they serve.Forum members are a leading source of credit to American companies.&nbsp; Importantly, Forum members provide corporate lending to an extremely wide swath of industries.&nbsp; The breadth of Forum member lending across the corporate spectrum is important because it allows Forum members to broadly support the economy.&nbsp; As economic conditions change and some industries grow more quickly than others, Forum members can leverage their breadth to effectively and efficiently channel lending to where it is needed most.&nbsp; &nbsp; &nbsp;In the chart below, we report the aggregate amount of credit provided by Forum members to companies through their lending activities.&nbsp; To be clear, this is only one important part of the story, since Forum members also underpin America’s capital markets, where credit and other critical services such as underwriting and risk management allow companies and their employees to thrive.<figure class="image image_resized" style="width:100%;"><img src="https://fsforum.com/a/media/blog-2.27.25.jpg"><figcaption>Source: Forum member 10-k disclosures</figcaption></figure>As can be seen in the chart above, Forum members’ lending activities are broadly distributed across various industry sectors.&nbsp; Forum members are lending nearly $600 billion to the Industrials sector that would include companies such as General Electric, Caterpillar, and Lockheed Martin to name a few.&nbsp; Forum members are also lending nearly $500 billion to the Consumer &amp; Retail sector which would include companies such as Walmart, Target, and Home Depot.&nbsp; In addition, Forum members are lending nearly $400 billion to the Technology, Media, and Telecom sector which would include companies such as Google, Amazon, and Cisco.&nbsp; These examples demonstrate the broad support that Forum members provide to help grow the economy, keep America competitive and support local communities.&nbsp;The roughly $4.8 trillion in direct lending from Forum members is a critical source of funds to drive investment and economic growth.&nbsp; Companies across the industry spectrum and across our country rely upon Forum members to invest in growth, provide income and benefits, and support American prosperity.&nbsp;Forum members support a dynamic, pro-growth policy agenda to ensure that American companies, workers, and individuals reap the benefits of the critical lending provided by our country’s leading banks.&nbsp;

Forum Lending Supports U.S. Economic Growth and Competitiveness

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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    

Dear reader,Welcome to the latest edition of The Forum File. In this edition, we are highlighting one bank’s work to expand affordable homeownership opportunities for people in underserved communities.We hope you enjoy reading this edition and please do not hesitate to share your feedback.Kevin Fromer, President and CEO, Financial Services Forum<h2>Penny for Your Thoughts</h2>Abigail Suarez, Head of Community Development, Corporate Responsibility<h3>Describe how JPMorganChase is taking a holistic approach to addressing the housing crisis.</h3>As a firm, we’re committed to expanding economic opportunity and driving inclusive economic growth. When communities thrive, our business does, too. The housing crisis is complex and requires multifaceted solutions, which is why our strategy aims to tackle both housing supply and demand constraints. We are leveraging our philanthropic dollars, business practices, and policy expertise as part of a coordinated, holistic approach to make housing more accessible and affordable. To give a recent example: in an effort to expand homeownership opportunities for underserved communities, we announced a $20 million philanthropic commitment to non-profit organizations working to address this issue, expanded access to a consumer lending product that provides eligible customers with lower interest rates or down payment assistance, and published policy recommendations for <a href="https://www.jpmorganchase.com/content/dam/jpmc/jpmorgan-chase-and-co/documents/advancing-affordable-sustainable-homeownership.pdf">Advancing Affordable, Sustainable Homeownership</a>. Our combined resources and expertise enable us to deliver impact alongside our local partners.<h3>JPMorganChase recently released a paper on <a href="https://www.jpmorganchase.com/content/dam/jpmc/jpmorgan-chase-and-co/documents/tackling-persistent-residential-vacancy-blight-and-abandonment.pdf">Tackling Persistent Residential Vacancy, Abandonment, &amp; Disrepair</a>, which outlined place-based strategies to tackle housing supply. How are you implementing these strategies in your own work?</h3>&nbsp;Households across the country are struggling to find affordable places to live, but the solutions to this issue vary depending on the market—in some areas the answer is <a href="https://www.jpmorganchase.com/newsroom/stories/2024-housing-supply-solutions">increasing housing production</a>, while other areas may need strategies to reactivate vacant or abandoned homes as safe places to live. This paper on residential vacancy is part of our What Works series, which shares insights and lessons learned drawn from our experience working with public, private and community partners to drive inclusive economic growth. The paper discusses the importance of&nbsp; building local capacity to address housing affordability challenges, a principle reflected in a $6 million commitment we made in Baltimore to increase affordable homeownership and stabilize housing supply. Our approach is informed by over half a decade of partnership with local city organizations and leaders who are finding innovative approaches to reduce the number of vacant homes in Baltimore. Working in silos is rarely effective, and we’re proud to show up in local communities as listeners and partners to tackle big challenges and catalyze progress.<h3>Another obstacle to homeownership is the problem of heirs property. Why is tackling heirs property important and what is JPMorganChase doing to address it?</h3>Homeownership is a primary means of building and passing wealth across generations—however, the issue of heirs property puts this at risk. Heirs property occurs when a homeowner dies without a will and their property is informally inherited by multiple descendants. Left unaddressed, this unstable homeownership status compromises the ability of residents to pass the property on to descendants and makes them vulnerable to foreclosure or a forced sale. To address this issue, we announced more than $9 million in philanthropic funding to support free legal assistance, estate planning services, and appraisal reform in underserved communities, as well as highlighted support for state and federal policy reforms to address this issue.&nbsp;We also published papers on <a href="https://www.jpmorganchase.com/content/dam/jpmc/jpmorgan-chase-and-co/documents/supporting-heirs-property-owners-through-natural-disaster-and-resiliency-programs.pdf">Supporting Heirs Property Owners Through Natural Disaster and Resiliency Programs</a> and <a href="https://www.jpmorganchase.com/content/dam/jpmc/jpmorgan-chase-and-co/documents/addressing-the-undervaluation-of-property.pdf">Solutions to Build Household Wealth by Addressing the Undervaluation of Property</a> to amplify insights and recommendations informed by our business, philanthropic, and policy expertise. By addressing the problem of heirs property, we can help more individuals benefit from the generational wealth-building power of homeownership.<h2>Value Add</h2>JPMorganChase announces plans to expand access to consumer, business and community banking services for customers across Iowa<figure class="image image_resized" style="width:82.6%;"><img src="https://fsforum.com/a/media/chase-heartland.png"></figure>JPMorganChase has committed to open more than <a href="https://media.chase.com/news/chase-makes-multi-billion-dollar-investment-in-its-branch-network">500 new branches, renovate approximately 1,700 locations and hire 3,500 employees across the country over the next three years</a>. This multi-billion dollar commitment will contribute to local economic growth through construction, ongoing community investments and local hiring, bringing opportunity to thousands of local residents.&nbsp;<a href="https://www.cnbc.com/2024/08/05/jpmorgan-chase-opens-more-small-town-branches-in-middle-america.html">As part of this nationwide expansion</a>, CEO Jamie Dimon, senior leaders from across the firm, community partners, employees and elected officials came together in Des Moines to announce the <a href="https://www.jpmorganchase.com/newsroom/press-releases/2024/jpmorganchase-expands-banking-services-in-iowa">expansion of the firm’s services to customers and communities across Iowa</a>. The firm’s Iowa footprint will expand from eight branches to more than 30 across the state by 2030, including new branches in Des Moines, Waterloo, Cedar Rapids, Sioux City, Iowa City and Ames. This commitment&nbsp;is part of the firm’s broader goal to serve 50% of the population in each of the 48 contiguous states within an accessible drive time and builds on 39 years of support for clients and communities in Iowa.<h2>Capital Gains</h2>What we’re doing in WashingtonForum President and CEO Kevin Fromer <a href="https://fsforum.com/news/forum-comments-on-reconsideration-of-capital-regulations">issued</a> a statement following Federal Reserve Vice Chair for Supervision Michael Barr’s remarks on U.S. capital regulations. “We look forward to reviewing the revisions and participating fully in the public comment process. Getting this right is essential for the U.S. economy,” Fromer said.<h2>Our Two Cents</h2>Research from the ForumThe BankNotes Blog Spotlighted:<ul><li>A report from the Government Accountability Office on the banking agencies’ regulatory analysis, which <a href="https://fsforum.com/news/playing-catch-up-on-cost-benefit-analysis-regulators-need-to-up-their-game-on-basel-iii-endgame">emphasizes</a> significant implications for finalizing the Basel III Endgame capital proposal.</li><li>The strong liquidity profile of Forum members and the need for thoughtful and data-based analysis before <a href="https://fsforum.com/news/getting-it-right-before-getting-it-done-large-bank-liquidity-regulation">proposing</a> new liquidity regulations for large banks.</li><li>A proposal by the Federal Reserve and global regulators through the Basel Committee on Banking Supervision to <a href="https://fsforum.com/news/gsib-scores-and-window-dressing-where-is-the-smoking-gun">increase</a> the cost and burden of GSIB score reporting, which is not supported by regulatory data on both GSIBs and non-GSIBs.</li></ul><h2>Checking the Balance</h2>Members in the NewsBank of America <a href="https://newsroom.bankofamerica.com/content/newsroom/press-releases/2024/07/bofa-celebrates-20-years-of-paid-summer-internship-program---stu.html">celebrated</a> two decades of supporting youth employment and economic opportunity through its signature philanthropic program, Student Leaders. The program has provided 4,500 students with work experience and leadership skills to help build future careers.BNY <a href="https://urldefense.com/v3/__https:/america250.org/news/america250-announces-first-ever-americas-field-trip-awardees/__;!!OiWDNh-9Pw!9ZfEqv9afxrLbGkEk59IdvjAw0JIn1F--1LTM1BDv5vMT2GbGhkwUt2qHWx4cskmLbNY2vmSRZo1KTU$">sponsored</a> America250’s “America’s Field Trip,” a nationwide scholastic contest encouraging students to reflect on what America means to them. The firm helped bring 75 students from 27 states and territories to the nation’s most historical and cultural landmarks including the New York Headquarters of BNY, the country’s oldest bank.Citi’s latest Securities Services Evolution whitepaper focuses on the next frontier for the industry with the growing applicability of technologies, including distributed ledger technology and digital assets, and the significant potential for tokenization. <a href="https://www.linkedin.com/posts/citi_securities-services-evolution-2024-disruption-activity-7236977206336401409-rIAX">Watch an explainer video</a> and read more on these developments that continue to transform the securities landscape <a href="https://www.citibank.com/icg/docs/Citi_Securities_Services_Evolution_2024.pdf?linkId=575991464">in the whitepaper</a>.Goldman Sachs 10,000 Small Businesses <a href="https://urldefense.com/v3/__https:/www.al.com/news/birmingham/2024/09/goldman-sachs-commits-3-million-to-boost-alabamas-small-rural-businesses.html__;!!O2kDR7mm-zSJ!tPfgEVHyVMku67u8Cx4uOF0ywOCofLR2DfFmxS2BzokhfvFOYXgNQH4C-BAS6r0xi7_JESNJCLAQFBSj$">announced</a> an expansion of the program to Alabama, which includes a $3 million commitment to community development financial institutions focused on small businesses, and marks the initiatives fifth launch state to date – on track to meet its goal of reaching 20 states in five years.JPMorganChase <a href="https://www.jpmorganchase.com/newsroom/press-releases/2024/jpmorganchase-unidos-philanthropic-commitment">announced</a> joint policy recommendations and a $6 million commitment to UnidosUS focused on building organization capacity and supporting homebuyer readiness, expanded access to credit, increased housing supply, and the preservation of Latino homeownership.Morgan Stanley celebrated the 2024 graduates of its <a href="https://www.morganstanley.com/about-us/supplier-diversity/small-business-academy1">Small Business Academy</a>, a partnership between its Supplier Diversity Program and the Institute for Inclusion. Through 12 weeks of instructor-facilitated learning and a year-long mentorship program, the Academy enables small businesses to differentiate themselves in the procurement process, strengthen their business acumen and expand their professional networks.State Street <a href="https://newsroom.statestreet.com/press-releases/press-release-details/2024/State-Street-Announces-Issuance-of-1-Billion-of-Senior-Debt/default.aspx">announced</a> an issuance of $1 billion of senior debt, which includes five broker-dealers owned by underrepresented groups who have underwritten 40% of the securities in the issuance.Wells Fargo <a href="https://stories.wf.com/wp-content/uploads/2024/07/Open-for-Business-Fund-Impact-Report-Fact-Sheet.pdf">shared</a> its recent community impact report of the company’s Open for Business Fund, a roughly $420 million national small business recovery effort to help those hardest hit during and after the COVID-19 pandemic. Launched in 2020, grantees report the Open for Business Fund has now benefited more than 336,000 small businesses, empowering them to keep or create more than 461,000 jobs in communities across the nation.

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The Forum File, 2024 Edition #5

Dear reader,Welcome to the latest edition of The Forum File. In this edition, we are highlighting one bank’s work to support underrepresented entrepreneurs.We hope you enjoy reading this edition and please do not hesitate to share your feedback.Kevin Fromer, President and CEO, Financial Services Forum<h2>Penny for Your Thoughts&nbsp;</h2>Selma Bueno is the Global Head of Morgan Stanley’s Inclusive Ventures Group<h3>Tell us about the Morgan Stanley Inclusive Ventures Lab and what makes it unique.</h3>The <a href="https://www.morganstanley.com/about-us/diversity/inclusive-ventures-lab">Morgan Stanley Inclusive Ventures Lab</a> was launched in 2017 to advance a more equitable investment landscape. We run a five-month accelerator program for founders of technology and technology-enabled startups in the seed to Series A funding round stage to develop and scale their businesses. In 2021, we expanded the Lab from North America to Europe, the Middle East and Africa, enabling us to support even more innovation and inclusion globally.&nbsp;What makes our program unique is its holistic approach to supporting portfolio companies. We invest $250,000 in each business, as well as provide a tailored curriculum, mentorship, networking, office space for the duration of the program and access to external advisors.To date, 92 companies, with a combined valuation of $923 million, have been through our accelerator program. The founders have collectively raised over $200 million in additional funding since their participation in the Lab.<h3>How does the Lab’s work align with Morgan Stanley’s Core Values?</h3>At Morgan Stanley, we are guided by five Core Values: do the right thing; put clients first; lead with exceptional ideas; commit to diversity and inclusion; and give back. I am proud to lead an initiative that integrates each of our values.The Lab was created to help shift the investment landscape and level the playing field for underrepresented entrepreneurs because it is the right thing to do, both for the founders we support and for the marketplace as a whole. By spotlighting innovative companies and giving them the platform and network they might need help accessing, we are driving innovation in business broadly.Our Lab’s cohort companies receive the full suite of Morgan Stanley resources and an ecosystem of internal and external partners to provide much-needed investment and guidance – as any client would. In connecting the founders with mentors and with one another, we are building a community in which previously overlooked entrepreneurs can succeed.<h3>Can you tell us how some of the Lab companies are driving inclusivity in the marketplace themselves?</h3>Many of our founders are leveraging their diverse backgrounds and communities’ values to address important gaps in the market and, in turn, advance a more equitable society.Some companies are working to tackle the critical issue of inequity in healthcare, like <a href="https://healthinherhue.com/">Health in Her HUE</a>, which connects Black women and women of color to culturally sensitive healthcare providers and <a href="https://www.gomedhaul.com/">MedHaul</a>, an online marketplace for healthcare providers to book non-emergency medical transportation for patients, based on their special needs.In the education tech space, <a href="https://imagilabs.com/">imagi</a> is using proprietary, inclusive education tools to empower kids to code, increase engagement among girls and help close the gender gap in tech early on.And <a href="https://www.zirtue.com/">Zirtue</a>, a relationship-based lending app that simplifies loans between friends and family, is making it easier than ever for people to access funds by tapping into the power of community support.What all of our cohort companies have in common, regardless of industry or product offering, is the founders’ innate desire to build a better world.&nbsp;<h2>Value Add</h2><figure class="image"><img src="https://fsforum.com/a/media/ivl-founders_crop-(002).jpg"></figure>The Inclusive Ventures Lab Demo Day is our annual showcase where founders can put all they have learned in the accelerator program to the test and raise their profiles with potential investors, business partners and customers.We hosted our ninth Demo Day in February for our largest audience yet of portfolio companies and potential investors. The investment firms in attendance represented over $40 billion of dry powder and indicated a high level of interest in the startups following the event.This latest showcase emphasized both market connectivity, with AI and sustainable solutions as cross-cutting themes, and the sheer range of innovation in our Lab, with companies representing industries such as healthcare, customer service, supply chain, recruiting and cybersecurity.In today’s challenging funding environment, it is incredibly important that we can provide our participating founders with the opportunity to attract capital, expand their networks and bring their game-changing products to scale.<h2>Capital Gains</h2>What we’re doing in Washington<figure class="image image_resized" style="width:79.95%;"><img src="https://fsforum.com/a/media/picture9.jpg"></figure>Forum Chief Economist Sean Campbell <a href="https://fsforum.com/news/icymi-transparency-in-stress-testing-essential-to-achieving-a-more-effective-efficient-and-resilient-financial-system">testified</a> before the House Financial Institutions and Monetary Policy Subcommittee on the need for greater transparency in the stress testing process. “Aligning stress tests with the public process afforded other bank regulatory standards would help improve public trust, promote economic stability, and ensure banks can support the economy to their fullest potential,” Dr. Campbell told lawmakers. Read Dr. Campbell’s full testimony <a href="https://fsforum.com/a/media/forum-dr.-sean-campbell-testifies-on-stress-testing_6.26.24.pdf">here</a> and learn more about stress testing <a href="https://fsforum.com/a/media/stress-testing-for-the-largest-us-banks.pdf">here</a>.&nbsp;Forum President and CEO Kevin Fromer <a href="https://fsforum.com/news/stress-tests-underscore-capital-strength-of-nation-s-largest-banks">issued</a> a statement in response to the Federal Reserve Board’s 2024 stress test results. “The results affirm that the additional capital requirements in the Basel III Endgame proposal are not justified,” Fromer said.The Forum <a href="https://fsforum.com/news/basel-changes-to-capital-surcharge-calculation-unwarranted">submitted</a> a comment letter on the proposed revisions to the methodology for capital surcharges for Global Systemically Important Banks to the Basel Committee on Banking Supervision. “Financial regulations that are not appropriately calibrated result in an inefficient financial system that misallocates capital in a way that can have a detrimental effect on the businesses and households that our member institutions serve, and on the U.S. and global economies as a whole, with no clear corresponding benefit to the resilience of the financial system,” the Forum said.<h2>Our Two Cents&nbsp;</h2>Research from the ForumThe Forum <a href="https://fsforum.com/a/media/forum-value-and-resiliency2024_q1.pdf">released</a> its latest data on the value and strength of the nation’s largest banks.<h2>Checking the Balance</h2>Members in the NewsThe Bank of America Boston Marathon Official Charity Program <a href="https://newsroom.bankofamerica.com/content/newsroom/press-releases/2024/05/128th-boston-marathon--presented-by-bank-of-america-raises-recor.html">raised</a> $45.7 million, contributing to the marathon’s record total of $71.9 million in charitable funds raised this year. The funds went toward nearly 160 non-profit organizations in the Greater Boston community.BNY <a href="https://linkprotect.cudasvc.com/url?a=https%3a%2f%2fwww.bnymellon.com%2fus%2fen%2fabout-us%2fnewsroom%2fcompany-news%2fthe-bank-of-new-york-mellon-corporation-introduces-updated-brand-bny.html&amp;c=E,1,klT35NUTsdUE8BdfT4UgWK1NuEOweXGzypcGVvsnG3INnu37FDoIoScI-Qc2tEiUAfOJodmwKYFxO1EsM5Re-Xc9fYsphx-mJKI0KwjsK55IQDvc&amp;typo=1">introduced</a> its new brand name and logo. The updated brand marks the firm’s evolution from America’s oldest bank, formerly known as BNY Mellon, to a global financial services leader.Citi Global Perspectives and Solutions <a href="https://www.citigroup.com/global/insights/citigps/ai-in-finance">published</a> a new report on AI &amp; Finance: Bot, Bank &amp; Beyond. The report analyzes the role that artificial intelligence might play in changing the way both consumers and companies bank.Goldman Sachs <a href="https://www.goldmansachs.com/our-firm/history/ipo-anniversary/index.html">commemorated</a> the 25th anniversary of its initial public offering. The firm’s leaders from past and present convened to ring the bell at the New York Stock Exchange.JPMorgan Chase <a href="https://www.jpmorganchase.com/newsroom/press-releases/2024/baltimore-philanthropic-commitment">announced</a> an $8.45 million philanthropic commitment to nonprofit organizations and programs across the city of Baltimore to support economic and community development. The funding addresses residential vacancies to stabilize the affordable housing supply, supports commercial corridor revitalization, and promotes small business growth.Morgan Stanley Foundation <a href="https://www.morganstanley.com/press-releases/morgan-stanley-foundation-8-million-grant-to-feeding-america#:~:text=Morgan%20Stanley%20(NYSE%3A%20MS),among%20children%20and%20underserved%20populations.">announced</a> an $8 million grant over four years to Feeding America to support the establishment or expansion of child and family feeding programs. Since 2009, Morgan Stanley’s funding for Feeding America has totaled more than $50 million, helping to deliver more than 356 million meals to children and families.State Street <a href="https://www.statestreet.com/us/en/asset-owner/insights/2024-markets-and-financing-research-retreat">hosted</a> its 2024 Markets and Financing Research Retreat. In collaboration with academic partners, guest speakers and strategists, the event dissected market trends, inflation, and other proprietary data-driven indicators.Wells Fargo Foundation <a href="https://newsroom.wf.com/English/news-releases/news-release-details/2024/100-Black-Men-of-America-and-Wells-Fargo-Expand-Junior-Investment-Club-with-600000-Grant/default.aspx">granted</a> $600,000 to 100 Black Men of America, a youth mentorship organization. This grant helps expand the organization’s Junior Investment Club, a curriculum-based simulation game that introduces young people to investing.

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The Forum File, 2024 Edition #4 

Dear reader,Welcome to the latest edition of The Forum File. In this edition, we are highlighting one bank’s work to help close the racial wealth gap and increase economic mobility for communities of color across the nation.We hope you enjoy reading this edition and please do not hesitate to share your feedback.Kevin Fromer, President and CEO, Financial Services Forum<h2>Penny for Your Thoughts</h2>Harold Butler is the head of Citi’s Diverse Financial Institutions Group<h3>Why did Citi set up a specific group to lead its work with diverse financial institutions?</h3>At Citi, our mission is to enable economic growth and progress. One of the most meaningful ways we are bringing this mission to life is through our commitment to help close the racial wealth gap and increase economic mobility for communities of color in the U.S.I have the privilege of leading Citi’s Diverse Financial Institutions Group – also known as DFIG – which helps institutionalize our company’s commitment to racial equity and serves as a centralized hub to lead and expand our engagement with diverse financial institutions.We know that diverse financial institutions are central to the financial services ecosystem. They are the trusted source of banking and access to capital for many communities across the country. At Citi, we are committed to supporting and strengthening these organizations to help scale this work.<h3>How does DFIG fit into Citi’s approach to using business integration to help address the racial wealth gap?</h3>We know from <a href="https://www.citigroup.com/global/insights/citigps/closing-the-racial-wealth-gap">our own research</a> that the mission of closing the racial wealth gap also presents great economic opportunity both for our country and for firms like Citi that lean into the upside. But we also knew making progress would require us to be intentional about our efforts and make a shift from a short-term, time-bound commitment to a longer-term outlook.By integrating DFIG into Citi’s Markets business, we are enabling Minority Depository Institutions (MDIs) and diverse broker-dealers to get involved in transactions that will grow fee and interest income for these firms. DFIG connects them with the right people at Citi who can make introductions and open up the chance for these firms to play a role in certain capital markets transactions where they might not typically have access or exposure. Citi’s DFIG is unique among Wall Street firms in playing this type of role.<h3>What brought you personally to this work?</h3>I didn’t cut my teeth as a banker. I worked on the sales side in technology at Freddie Mac and Microsoft before transitioning to banking. A professional connection brought me to Citi and I’m a big believer in building a business or a career through relationships with trusted professionals.I got into the DFIG work because we were trying to help one of Citi’s largest clients meet a goal it had related to inclusion for its suppliers. I saw a chance to leverage some of the relationships I cultivated over time to help our client achieve its goals. This helped to fuel what is now DFIG.<h3>How has this work progressed over the last couple of years since Citi originally launched DFIG in 2022?</h3>I know that the day-to-day engagements in Citi DFIG are contributing to closing the racial wealth gap. It is obviously going to take time, but we can feel things are changing. The 13 MDIs that Citi is supporting through equity investments are now positioned better than they’ve been in 40 years. That’s saying something.We’ve learned a lot over the past few years about the challenges many underserved communities are facing. That information empowers us to think about how we do business differently. Banks are the heartbeat of communities. Much like the heart pumps blood to the different parts of the body, investments in communities act much the same way and banks are the catalyst for making that happen.<h2>Value Add</h2>Citi Convenes Executives and Policymakers for DFIG Summit<figure class="image image_resized" style="width:100%;"><img src="https://fsforum.com/a/media/jane-and-steve-benjaminv2.jpg"></figure>The second annual Citi DFIG Executive Summit brought together leaders from more than 80 MDIs and diverse broker dealers and asset managers at the Landsdowne Resort in Leesburg, Virginia, in early May. After launching the summit last year at Citi’s headquarters in New York, the second edition held closer to the nation’s capital enabled several policymakers to participate and share their perspectives on the government’s role in advancing this work.Citi CFO Mark Mason kicked off the conversation in a fireside chat with U.S. Treasury Deputy Secretary Wally Adeyemo while Citi CEO Jane Fraser and Steve Benjamin, Senior Advisor to the President and Director of the White House Office of Public Engagement, spoke to attendees over lunch. Finally, U.S. Deputy Commerce Secretary Don Graves sat down with Jarryd Anderson, co-chair of the Financial Services Group at Paul, Weiss, to talk about the public-private partnership to advance economic growth.Participants also heard from Citi leaders and other outside experts on industry trends, training platforms and innovative solutions to common challenges. Breakout sessions tailored to participant interests and social components of the programming fostered the networking and collaboration that are pillars of the DFIG approach.This annual gathering serves to further drive Citi DFIG’s mission of working with our partners to create revenue-generating opportunities, share expertise, and drive an even greater impact in diverse communities.<h2>Capital Gains</h2>What we’re doing in WashingtonIn our latest BankNotes Blog, Forum Chief Economist and Head of Policy Research, Sean Campbell, <a href="https://fsforum.com/news/federal-reserve-financial-stability-report-underscores-strength-of-america-s-largest-banks-and-wayward-regulatory-policy">examined</a> how the Federal Reserve’s Financial Stability Report underscores the strength of the nation’s largest banks through their strong levels of capital and liquidity. “The Federal Reserve and other regulators should take stock of its own financial stability assessment as they chart the course for regulatory reform,” Campbell wrote.The Forum <a href="https://fsforum.com/a/media/fsf_factsheet_impact-on-muni-bonds.pdf">released</a> a fact sheet on Basel III Endgame’s impact on municipal bonds.<h2>Our Two Cents</h2>Research from the ForumThe Forum <a href="https://fsforum.com/a/media/forum-value-and-resiliency_2023q4.pdf">released</a> its latest data on the value and strength of the nation’s largest banks.<h3>Checking the Balance</h3>Members in the newsBank of America <a href="https://newsroom.bankofamerica.com/content/newsroom/press-releases/2024/03/new-bofa-platform-connects-small-businesses-to-cdfi-capital-and-.html">launched</a> a new Access to Capital Connector, an online platform designed to connect entrepreneurs and small business owners to local Community Development Financial Institutions and other business support organizations.BNY Mellon <a href="https://www.bnymellon.com/us/en/about-us/newsroom/press-release/bny-mellon-collaborates-with-accenture-to-drive-accelerated-growth-for-clients-130384.html">collaborated</a> with Accenture, a leading professional services company, to modernize financial services offerings and help their joint clients drive growth.Citi CEO Jane Fraser <a href="https://www.cnbc.com/2024/05/07/biden-set-to-meet-with-executives-from-citi-united-airlines-others.html">joined</a> other business executives in a White House meeting with President Biden to discuss the economy with a focus on supporting businesses and workers.Goldman Sachs <a href="https://www.goldmansachs.com/media-relations/press-releases/2024/fourth-annual-market-madness-competition.html">held</a> its fourth-annual Market Madness competition, a program dedicated to supporting students at Historically Black Colleges and Universities and granted $1 million to Spelman College.JPMorgan Chase <a href="https://www.jpmorganchase.com/news-stories/20million-housing-affordability-commitment">announced</a> $20 million in new philanthropic funding to eight organizations across the U.S. working to expand homeownership opportunities for underserved communities. Additionally, the firm is expanding its Chase Home Lending program, increasing the homebuyer grant from $5,000 to $7,500 in 8,500 neighborhoods across the U.S.Morgan Stanley <a href="https://www.morganstanley.com/press-releases/morgan-stanley-strengthens-alliance-for-children-s-mental-health">announced</a> a $20 million commitment over the next five years to its Alliance for Children’s Mental Health, bringing the firm’s total funding to $50 million since launch in 2020. The Alliance will strengthen its work delivering programming and research, as well as advancing solutions through its Innovation Awards.State Street <a href="https://newsroom.statestreet.com/press-releases/press-release-details/2024/State-Street-Earns-MLTs-Hispanic-Equity-at-Work-Bronze-Certification-and-Black-Equity-at-Work-Bronze-Recertification/default.aspx">earned</a> the Hispanic Equity at Work Bronze Certification and the renewal of its Black Equity at Work Bronze Certification by Management Leadership of Tomorrow, a non-profit dedicated to advancing racial equity in the workplace.Wells Fargo Home Lending <a href="https://newsroom.wf.com/English/news-releases/news-release-details/2024/Wells-Fargo-Expands-Down-Payment-Grant-Program-to-Help-Bridge-Homeownership-Gap/default.aspx">expanded</a> its $10,000 Homebuyer Access grant program to additional communities in the eight metropolitan areas where the program was launched in 2023. This expansion provides greater opportunities for Black and Hispanic homebuyers and helps increase homeownership for underserved communities.&nbsp;

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The Forum File, 2024 Edition #3

The Forum File

Contact: Laura Peavey&nbsp;&nbsp;(202) 457-8770&nbsp;lpeavey@fsforum.com&nbsp;Forum Applauds House Committee Passage of Measures to Improve Bank SupervisionWashington D.C. – Financial Services Forum President and CEO Kevin Fromer issued the following statement after the House Financial Services Committee voted today to advance the Financial Integrity and Regulation Management (FIRM) Act, the Fair Audits and Inspections for Regulators’ (FAIR) Exams Act, and the Halting Uncertain Methods and Practices in Supervision (HUMPS) Act:“We appreciate the House Financial Services Committee for advancing common sense legislation that brings greater clarity and helps create a more effective and efficient supervisory environment for financial institutions and the customers they serve. The FIRM Act, the FAIR Exams Act, and the HUMPS Act represent important steps toward a supervisory system that is consistent and transparent.”The FIRM Act, sponsored by Rep. Andy Barr, removes reputational risk as a factor in federal bank supervision, ensuring oversight is based on objective financial measures.The FAIR Exams Act, sponsored by Chairman French Hill, strengthens the review process for supervisory decisions by allowing independent appeals, promoting fairness and accountability.The HUMPS Act, sponsored by Rep. Scott Fitzgerald, enhances the evaluation of banks by requiring clearer standards and more consistent application of ratings.###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>

Press Releases

Forum Applauds House Committee Passage of Measures to Improve Bank Supervision

Financial Associations Urge Federal Reserve to Address Potential Uncertainty Caused by Stress Capital Buffer Proposal Timing"The timing of the proposal will create uncertainty in the stress capital buffer requirements”Washington D.C. – A coalition of financial services trade associations urged the Federal Reserve Board (FRB) to take prompt, interim steps that clarify the operation of the 2025 stress test cycle and related stress capital buffer (SCB) requirements to avoid unnecessary uncertainty. &nbsp;The associations include the Financial Services Forum, American Bankers Association, Bank Policy Institute, and Securities Industry and Financial Markets Association.On April 17th, the FRB proposed changes to the stress testing regime effective for 2025 which include averaging stress capital buffer requirements and a change in the effective date of the requirements, with comments due on June 23rd. In a joint letter, the associations explained that since a final rule will not be in place by the time that stress test results are released on June 30th, firms will be unable to accurately communicate their tentative stress capital buffers or capital actions.&nbsp; &nbsp;To address this issue, the associations recommend the FRB take action prior to the 2025 stress test results that allows firms to base their upcoming SCB solely on their 2025 stress test results to ensure accurate SCB calculations, provide reliable dividend payment disclosures, and prevent public confusion.“To avoid introducing additional uncertainty regarding the SCB requirement, which would be inconsistent with the Proposal’s stated purpose, we urge that the FRB, no later than 14 calendar days before the scheduled date for the announcement of 2025 stress testing results, publicly announce that firms will be permitted to operate under the existing SCB framework through September 30, 2026, regardless of whether the FRB adopts revised SCB mechanics in a final rule with an effective date in that window,” the associations stated.The full letter can be found <a href="https://fsforum.com/a/media/joint-trades-letter-sbc-timing.pdf">here</a>.Media Contacts:Laura PeaveyFinancial Services Forumlpeavey@fsforum.comJosh BrittonAmerican Bankers Associationjbritton@aba.comAustin AntonBank Policy Instituteaustin.anton@bpi.comLindsay GilbrideSecurities Industry and Financial Markets Associationlgilbride@sifma.orgAbout Financial Services ForumThe Financial Services Forum is an economic policy and advocacy organization whose members are the eight largest and most diversified financial institutions headquartered in the United States. Forum member institutions are a leading source of lending and investment in the United States and serve millions of consumers, businesses, investors, and communities throughout the country. The Forum promotes policies that support savings and investment, financial inclusion, deep and liquid capital markets, a competitive global marketplace, and a sound financial system.About American Bankers AssociationThe American Bankers Association is the voice of the nation’s $24.1 trillion banking industry, which is composed of small, regional and large banks that together employ approximately 2.1 million people, safeguard $19.2 trillion in deposits and extend $12.7 trillion in loans.About Bank Policy InstituteThe Bank Policy Institute is a nonpartisan public policy, research and advocacy group that represents universal banks, regional banks and the major foreign banks doing business in the United States. The Institute produces academic research and analysis on regulatory and monetary policy topics, analyzes and comments on proposed regulations, and represents the financial services industry with respect to cybersecurity, fraud, and other information security issues.About Securities Industry and Financial Markets AssociationSIFMA is the leading trade association for broker-dealers, investment banks and asset managers operating in the U.S. and global capital markets. On behalf of our industry’s one million employees, we advocate on legislation, regulation and business policy affecting retail and institutional investors, equity and fixed income markets and related products and services. We serve as an industry coordinating body to promote fair and orderly markets, informed regulatory compliance, and efficient market operations and resiliency. We also provide a forum for industry policy and professional development.&nbsp; SIFMA, with offices in New York and Washington, D.C., is the U.S. regional member of the Global Financial Markets Association (GFMA).&nbsp;###

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

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

Stress Tests

Financial Associations Urge Federal Reserve to Address Potential Uncertainty Caused by Stress Capital Buffer Proposal Timing

&nbsp;CONTACT: Laura Peavey(202) 457-8770lpeavey@fsforum.com&nbsp;Forum Applauds Senate Committee Approval of Governor Bowman for Vice Chair for SupervisionSwift Senate confirmation of Bowman and OCC nominee Gould is crucialWashington, D.C. – Financial Services Forum President and CEO Kevin Fromer issued the following statement after the Senate Banking Committee voted today to advance Federal Reserve Governor Michelle Bowman’s nomination for Federal Reserve Vice Chair for Supervision:“We appreciate the Senate Banking Committee’s action to approve President Trump’s nominee for Vice Chair for Supervision, Michelle Bowman. This role is critical to implementing appropriate regulation and effective supervision that promotes economic growth. America’s leading banks urge swift action by the full Senate to confirm Governor Bowman and Comptroller of the Currency nominee Jonathan Gould, who previously was approved by the committee. They are well-qualified nominees and it is crucial that these roles be filled.”###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: <a href="http://www.fsforum.com/">fsforum.com</a>Follow us on X <a href="https://twitter.com/fsforum">@fsforum</a> and <a href="https://www.linkedin.com/company/financial-services-forum/">LinkedIn</a>

Forum Applauds Senate Committee Approval of Governor Bowman for Vice Chair for Supervision

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Kevin Fromer

President and Chief Executive Officer

This op-ed was featured in <a href="https://www.americanbanker.com/opinion/basel-myths-are-all-too-real-for-the-financial-services-industry">American Banker</a>.&nbsp;To the editor,In a recent BankThink ("<a href="https://www.americanbanker.com/opinion/debunking-the-myths-about-the-basel-iii-endgame-regulation">Debunking the myths about the Basel III endgame regulation</a>," Jan. 18, 2024), the author is absolutely correct that the conversation about the possible increase in capital requirements must be based on facts. But from the very first sentence, the piece is filled with inaccuracies.First, just a<a href="https://www.bis.org/bcbs/implementation/rcap_reports.htm"> handful</a> of countries have implemented the agreement struck in Basel, Switzerland, in 2017. Like the United States, most of the jurisdictions around the world are at various stages of creating their rules. Thus far, the United States is proposing to increase capital to a<a href="https://fsforum.com/a/media/key-takeaways-b3e-comments.pdf"> much larger degree</a> for its global systemically important banks (GSIBs) than other jurisdictions. The U.K. is proposing a 3.2% increase for its GSIBs versus a 5.6% increase for the EU and an estimated 30% for U.S. GSIBs. The U.S. proposal's many inconsistencies with the international Basel agreement and Basel III endgame proposals in other jurisdictions would worsen, rather than improve, already substantial international discrepancies in capital requirements. Such divergences would harm the American economy and the ability of U.S. companies to compete internationally. So much for the stated goal of harmonizing international capital rules.Second, the implementation of the Basel III endgame for the largest U.S. banks has absolutely nothing to do with the regional banking turmoil last year. To the contrary, because of their strong capital positions, the largest U.S. banks were called upon by the government to step in and support the financial sector in March, putting billions of dollars of unsecured deposits into First Republic Bank to squelch contagion and give the Federal Deposit Insurance Corp. time to wind down the ailing institution.Federal Reserve Chair Powell has<a href="https://www.youtube.com/watch?v=627kC040sPU"> said</a> repeatedly that the nation's largest banks are "very strong" and a "source of strength." The largest U.S. banks have supported small and large businesses, households and communities, and helped to ensure smooth functioning financial markets during significant economic headwinds, such as the COVID-19 pandemic. In the past 15 years, U.S. GSIBs have more than tripled their common equity tier 1 capital to more than $900 billion. The largest U.S. banks also are subject to annual supervisory stress testing and have maintained capital<a href="https://www.federalreserve.gov/newsevents/pressreleases/bcreg20230628a.htm"> well in excess</a> of hypothetical losses estimated by those stress tests. These tests assume no emergency government support during an economic downturn.Finally, contrary to the author's statements, the largest U.S. banks and their more than 735,000 employees are<a href="https://fsforum.com/our-impact/essential-to-the-u-s-economy"> essential</a> to the strength and the competitiveness of the U.S. economy, supporting countless American households, businesses and governments every day, including those in historically underserved communities. In just one example, Forum members have invested more than $9.2 billion in Community Development Financial Institutions and committed more than $525 million to minority depository institutions since the beginning of 2020.The<a href="https://www.fdic.gov/resources/regulations/federal-register-publications/2023/2023-regulatory-capital-rule-large-banking-organizations-3064-af29.html"> comment letters</a> in response to the proposal are still coming in, but organizations across the country — including the NAACP, small businesses, manufacturers, local lawmakers and others — have raised concerns with the Basel endgame proposal, including its potential impact on people in historically underserved communities.The financial crisis was 15 years ago. The nation's largest banks are strong and they are essential to our economy. Higher capital requirements would do more harm than good. And that's a fact.&nbsp;Kevin Fromer is the President and CEO of the Financial Services Forum. &nbsp;

Opinion

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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 

Letter to the editor: Basel 'myths' are all too real for the financial services industry

This article originally appeared on <a href="https://fortune.com/2023/12/06/us-economy-could-face-perfect-storm-basel-iii-endgame-goes-into-effect-finance-banks-kevin-fromer/">Fortune</a>.&nbsp;The past three years of economic volatility have exacted a profound toll on many Americans, testing the resilience of households and businesses alike. During this period, the largest banks, fundamentally strengthened by a series of changes, have served as a source of support by extending enormous amounts of credit, helping customers navigate uncertainty, and stabilizing the broader banking sector at a critical moment. Now, as the CEOs of these banks gather on Capitol Hill, Congress must ask itself if proposed regulations on capital jeopardize the essential work of these institutions.The capital regulation plan known as Basel III Endgame will increase capital requirements by 20% or more for the eight largest U.S. banks. This is an excessive move, considering the <a href="https://fsforum.com/a/media/capital-and-the-nation%E2%80%99s-largest-banks.pdf">tripling</a> of high-quality capital for these banks over the past 15 years. Higher capital requirements, <a href="https://www.federalreserve.gov/newsevents/pressreleases/powell-statement-20230727.htm">as noted by Federal Reserve Chair Jerome Powell</a>, raise the cost of–and reduce access to–credit.The plan will certainly compound the burden of higher post-pandemic interest rates,&nbsp;<a href="https://www.urban.org/sites/default/files/2023-09/Bank%20Capital%20Notice%20of%20Proposed%20Rulemaking.pdf?utm_source=newsletter&amp;utm_medium=email&amp;utm_campaign=newsletter_axiosmarkets&amp;stream=business">particularly for those with lower incomes</a>. Americans will have a harder time getting a loan, securing a mortgage, or saving for their retirement or a child’s college education.The impact isn’t limited to individual consumers. Small businesses&nbsp;<a href="https://fsforum.com/news/capital-insights-new-bank-capital-rules-will-handicap-small-businesses">relying</a>&nbsp;on credit and farmers&nbsp;<a href="https://www.americanbanker.com/opinion/basel-endgame-will-drive-up-costs-for-american-farmers-and-consumers">needing</a>&nbsp;funds for operations and equipment will face difficulty securing much-needed capital.A chorus of voices from the left and the right have come out against this proposed rule. Bipartisan consensus is rare these days, so the growing coalition of policymakers, advocacy groups, and community leaders warning against the negative impacts of stricter capital requirements is not something to take lightly. Senator&nbsp;<a href="https://www.politico.com/newsletters/morning-money/2023/09/14/the-calls-are-coming-from-inside-the-house-dems-rap-biden-bank-cops-00115837">Mark Warner (D-Va.)</a>&nbsp;has emphasized the potential compounding effect of tougher capital standards, high interest rates, and disruptions in the commercial real estate market as a “perfect storm.” Senator&nbsp;<a href="https://financialservices.house.gov/calendar/eventsingle.aspx?EventID=409027">John Tester (D-Mont.)</a>&nbsp;stated that he is worried about how this will impact working Americans, explaining he has “some concerns about the proposed changes, and what its impact will be on workers and households, small businesses, access to credit, and the overall vibrancy of our capital markets.”&nbsp;In a&nbsp;<a href="https://www.banking.senate.gov/imo/media/doc/basel_iii_banking_gop_letter.pdf">letter</a>&nbsp;to regulators, 39 Senate Republicans, led by Senator Tim Scott (R-S.C.), highlighted the resilience of the well-capitalized U.S. banking system and argued the proposal would negatively impact the economy while making credit costlier and more difficult to obtain for millions of Americans.Given these concerns, it is fair to ask why capital increases of this size are necessary. But no one seems equipped to provide an answer. On the contrary, the predominant official assessment of the banking sector, and the largest banks in particular, has been laudatory. As a matter of fact, every hypothesized loss the proposal aims to address has been experienced under real-life stress tests such as the pandemic, and the largest U.S. banks have continued to support the economy despite those losses under current capital requirements.Reflecting on the years of reform under the Dodd-Frank Act and Basel III, Chair Powell&nbsp;<a href="https://www.youtube.com/watch?v=627kC040sPU">highlighted</a>&nbsp;improvements in the banking system’s resilience, stating, “The large banks in the United States are very strong, well-capitalized, a lot of liquidity and they’ve been a source of strength, I think, through the last couple of events.”The future path of the U.S. economy is far from certain and hardworking Americans will pay a price if regulators demand new, unjustified capital requirements. Policymakers must demand extensive changes to the Basel III Endgame proposal so the banking sector can continue its essential role in the U.S. economy–and to avoid taxing consumers and businesses for no appreciable benefit to financial stability.Kevin Fromer is the president and CEO of Financial Services Forum.

Op-ed: The U.S. economy could face ‘a perfect storm’ if Basel III Endgame goes into effect. Here’s why

This op-ed was featured in the <a href="https://www.americanbanker.com/opinion/dont-delay-public-input-on-feds-review-of-capital-requirements">American Banker's BankThink.&nbsp;</a>&nbsp;<blockquote>Last month, Federal Reserve Vice Chair for Supervision Michael Barr outlined the Federal Reserve's agenda to make the financial system safer and fairer by improving banks' safety and soundness. Barr <a href="https://www.federalreserve.gov/newsevents/speech/barr20220907a.htm">called for a holistic review</a> of the bank capital framework, including a review of leverage and capital requirements for large banks. We welcome the Fed's review. And we urge the Fed to be more transparent about it.</blockquote>Mr. Barr is right. Currently, the U.S. capital framework is comprised of a dizzying array of moving parts: risk-weighted assets, stress capital buffers, surcharges on global systemically important banks, countercyclical buffers and leverage buffers, just to name a few. All these requirements are implemented separately, sometimes with several years between rules. No singular element of the capital regime determines overall capital requirements — rather, the various constraints knit together in complex and unpredictable ways to determine the overall amount of capital required of large banks. Given that capital requirements strongly influence the cost and amount of lending by banks in our economy, getting the mix of requirements right is critical, as is transparency around this process.&nbsp; Right now, all we know is that the Fed expects to complete its review this fall, and will only seek public input on proposed capital rules that are informed by the findings of the review after it is complete. We don't know much about how the review is being conducted, but we do know it is happening quickly — and without public input. But waiting for public input until so late in the game — once the direction of travel is set — is too late and risks consequential errors based on a lack of full information. The Federal Reserve should commit to seeking public feedback on its holistic review of the capital framework before the review is finalized and before any subsequent capital rules are proposed. Public feedback is crucial for several reasons.&nbsp; First, regulators' analysis can be improved by taking input from a variety of stakeholders, including academics and practitioners with significant expertise in bank capital.&nbsp; Second, public input will help ensure an evenhanded approach in reviewing the capital framework. A review solely conducted by regulators runs the risk of tipping the scales in a direction confirming existing policy preferences, even if there may be data supporting other perspectives.&nbsp; For example, studies have found that central bank-sponsored research on quantitative easing's effectiveness is more positive than other research on the topic. A full, open review of the capital framework soliciting input from a wide array of stakeholders will help ensure a thorough, unbiased and informed assessment.&nbsp; Most important, any study of the capital framework either implicitly or explicitly embeds a value judgment about the appropriate trade-off between economic growth and financial stability. Regulators are charged with maintaining financial stability, but they are not solely in charge of determining how society balances safety versus growth. Finding the right balance between growth and stability requires weighing the costs and benefits of additional financial stability measures against the impact on job creation and living standards. That debate must be informed by the views of all relevant stakeholders. The Federal Reserve and other agencies reviewing regulations routinely do so with public input. At least every 10 years, the bank regulatory agencies are <a href="https://egrpra.ffiec.gov/">required</a> by federal law to gather public input and review existing regulations. During the last cycle, regulators traveled the country for in-person meetings and collected written feedback. At one of these meetings, Federal Reserve Board Chairman Jay Powell <a href="https://www.federalreserve.gov/newsevents/speech/powell20150204a.htm">explained that</a> creating balanced, effective and thoughtfully calibrated regulations to avoid undue burden requires input from stakeholders. Researchers' review of the capital framework should also adhere to existing transparency standards for published academic research — and all of the data and analysis should be made public. The economics literature is replete with examples of studies that came to drastically incorrect conclusions because of simple data errors that were later uncovered by other researchers. Most academic journals now require that the data and programs used to conduct any analysis be made public before the results are published.&nbsp; The stakes are too high to accept even a small probability of an errant mistake. A comprehensive review of the capital framework and soliciting public input are necessary to ensure a safe and sound banking system in balance with the promotion of economic growth. Doing one without the other will be counterproductive — and risks reaching an outcome that does not reflect the needs of our economy.&nbsp;

BankThink Op-ed: Don't Delay Public Input on Fed's Review of Capital Requirements

Letters

Joint Trades Letter on Stress Capital Buffer Proposal 

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The Forum supports the development of international standards that utilize the existing framework for banking assets when considering how to treat crypto assets for capital, liquidity and other regulations.

Digital Assets

Joint Trades Letter to PWG on Digital Assets Next Steps Recommendations

Joint Trades Letter to PWG on Digital Assets

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The Role of Big Banks in Community Infrastructure

Forum President and CEO Kevin Fromer highlights how the nation's largest banks fund essential community infrastructure projects, showcasing their commitment to fostering growth and prosperity in America's cities and counties.

Video

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Big Banks and Their Role in Small Business Lending  

Forum President and CEO Kevin Fromer discusses the vital role played by the nation's largest banks in supporting small businesses through lending, and the significance of meeting the needs of American companies as the foundation for a strong economy. 

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Understanding the Role of Big Banks in American Competitiveness

Forum Chief Economist Sean Campbell discusses the important role that the nation’s biggest banks play in helping American companies compete internationally and explains how American international competitiveness is critical to ensuring the success and vibrancy of the U.S. economy.

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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

Videos

Fact Sheet

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While continuing to support the traditional energy sector, the nation’s largest banks are financing the transition to a less carbon-intensive economy. Many of the traditional energy companies, and other companies as well, are pursuing opportunities for the more renewable, less carbon-intensive energy sources that will power our economy in the future. Forum members are committed to an “all of the above strategy” that finances our nation’s transition to a cleaner and more renewable energy future while also working to ensure that today’s energy’s needs can be met effectively and efficiently.


Energy Finance

Nation’s Largest Banks Supporting Energy Needs of Today and Tomorrow

The Nation's Largest Banks by the Numbers

Capital and the U.S. Economy 

Fact Sheets

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Financial Associations Recommend Action to Remove Barriers to Digital Assets InnovationWashington, D.C. — &nbsp;A coalition of financial services trade associations urged the President’s Working Group on Digital Asset Markets to support efforts to remove barriers to financial institutions engaging in digital asset activities. The associations include the Bank Policy Institute, American Bankers Association, American Fintech Council, Americas Focus Committee of the Association of Global Custodians, Financial Services Forum, Securities Industry and Financial Markets Association and The Clearing House Association.In a joint letter, the associations acknowledge the meaningful progress the Federal Reserve, the FDIC and the OCC have made in rescinding policies and guidance that have hindered banks’ ability to engage in digital asset activities. The associations recommend additional steps that the banking agencies can take to advance bank innovation further.“The U.S. will not be able to achieve a leadership position in digital assets and financial technology under the status quo,” the letter states. “Banks are an essential component of the financial and payments systems and are governed by a comprehensive regulatory framework carefully crafted to mitigate the risks inherent to financial activities. It is therefore critical that the federal banking agencies take further steps to facilitate banks’ ability to engage in digital asset activities.”The associations made three key recommendations in the letter:<ol><li>Create consistent rules across agencies. The federal banking agencies should coordinate to issue joint rules and guidance when possible. If joint guidance isn't possible, the agencies should at least align their policies to avoid conflicting requirements.</li><li>Regulate the activity, not the technology. The agencies should affirm that banks may engage in permissible banking activities regardless of the technology used. A tokenized asset is no different from the traditional form of that asset; therefore, the regulatory framework should be technology-neutral.</li><li>Set clear risk-management expectations. Rather than requiring individual institutions to obtain permission from their regulator prior to engaging in digital asset activities, the agencies should issue uniform expectations for how institutions should manage the risks of those activities, including anti-money laundering, capital and liquidity risks.</li></ol>The associations’ recommendations are aligned with the objectives outlined in the President’s Executive Order on Digital Asset Markets and build on their February 20, 2025, <a href="https://bpi.com/financial-institutions-support-administrations-effort-to-maintain-u-s-leadership-in-digital-assets/">letter to the PWG</a>. While the banking agencies have addressed many of the recommendations, the associations continue to urge the Federal Reserve to revise its Policy Statement on Section 9(13) of the Federal Reserve Act and to rescind SR 23-7, “Creation of a Novel Activities Supervision Program.”To access a copy of the letter, please&nbsp;<a href="https://fsforum.com/a/media/digital-assets-2025-pwg-next-steps-.pdf">click here</a>.Media Contacts:Austin AntonBank Policy Instituteaustin.anton@bpi.comSarah GranoAmerican Bankers Associationsgrano@aba.comAmerican Fintech CouncilPress@FintechCouncil.orgWalter PalmerAmericas Focus Committee of the Association of Global Custodianswalter.palmer@us.bnpparibas.comLaura PeaveyFinancial Services Forumlpeavey@fsforum.comKatrina CavalliSecurities Industry and Financial Markets Associationkcavalli@sifma.orgGreg MacSweeneyThe Clearing House Associationgregory.macsweeney@theclearinghouse.orgAbout Bank Policy InstituteThe Bank Policy Institute is a nonpartisan public policy, research and advocacy group that represents universal banks, regional banks and the major foreign banks doing business in the United States. The Institute produces academic research and analysis on regulatory and monetary policy topics, analyzes and comments on proposed regulations, and represents the financial services industry with respect to cybersecurity, fraud and other information security issues.About American Bankers AssociationThe American Bankers Association is the voice of the nation’s $24.1 trillion banking industry, which is composed of small, regional and large banks that together employ approximately 2.1 million people, safeguard $19.2 trillion in deposits and extend $12.7 trillion in loans.American Fintech CouncilA standards-based organization, AFC is the premier trade association representing the largest financial technology (Fintech) companies and innovative banks. Our mission is to promote a transparent, inclusive, and customer-centric financial system by supporting responsible innovation in financial services and encouraging sound public policy. AFC members foster competition in consumer finance and pioneer products to better serve underserved consumer segments and geographies.About Americas Focus Committee of the Association of Global CustodiansEstablished in 1996, the Association of Global Custodians is a group of 12 financial institutions that provide securities safekeeping services and asset-servicing functions to primarily institutional cross-border investors worldwide. As a non-partisan advocacy organization, the Association represents members’ common interests on regulatory and market structure matters through comment letters, white papers and interaction with legislative and regulatory authorities and financial industry organizations. The member banks are competitors, and the Association does not involve itself in member commercial activities or take positions concerning how members should conduct their custody and related businesses. The Americas Focus Committee operates as an overarching full committee to address all Association matters involving regulatory/market structure issues arising in North or Latin America. About Financial Services ForumThe Financial Services Forum is an economic policy and advocacy organization whose members are the eight largest and most diversified financial institutions headquartered in the United States. Forum member institutions are a leading source of lending and investment in the United States and serve millions of consumers, businesses, investors, and communities throughout the country. The Forum promotes policies that support savings and investment, financial inclusion, deep and liquid capital markets, a competitive global marketplace, and a sound financial system.About Securities Industry and Financial Markets AssociationSIFMA is the leading trade association for broker-dealers, investment banks and asset managers operating in the U.S. and global capital markets. On behalf of our industry’s one million employees, we advocate on legislation, regulation and business policy affecting retail and institutional investors, equity and fixed income markets and related products and services. We serve as an industry coordinating body to promote fair and orderly markets, informed regulatory compliance, and efficient market operations and resiliency. We also provide a forum for industry policy and professional development.&nbsp; SIFMA, with offices in New York and Washington, D.C., is the U.S. regional member of the Global Financial Markets Association (GFMA).About The Clearing House AssociationThe Clearing House Association L.L.C., the country’s oldest banking trade association, is a nonpartisan organization that provides informed advocacy and thought leadership on critical payments-related issues. Its sister company, The Clearing House Payments Company L.L.C., owns and operates core payments system infrastructure in the United States, clearing and settling more than $2 trillion each business day.

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Financial Associations Recommend Action to Remove Barriers to Digital Assets Innovation

Member News

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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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