The world is being quietly rearranged by people who write very long documents.


The title they went with Regulatory Capital Rule (Regulation Q): Risk-Based Capital Surcharges for Global Systemically Important Bank Holding Companies; Systemic Risk Report (FR Y-15) Noisy translates that to

Megabanks must now hold more capital — the formula hasn't changed since 2008


The US central bank is rewriting how it calculates the extra capital that the largest banks must hold in reserve. The change makes those surcharges track actual risk more closely instead of staying frozen around outdated financial conditions, and it forces banks to average their risk metrics over time instead of gaming a single measurement date.
For a decade, the biggest banks have operated under capital rules built on 2008-era financial conditions and 2010s economic assumptions. This proposal updates those assumptions and, more importantly, closes a loophole: banks could temporarily shrink their riskiest positions on the one day per year the US central bank measured them, then rebuild those positions the next day. Averaging measurements over time kills that move. The surcharge formula itself gets recalibrated annually for inflation and real growth, which means the rules stop drifting further from reality as the economy changes. This is structural — it's not a new rule, it's a rule that actually responds to what banks are doing.
Every large US bank that modeled capital requirements under the old static formula now has to redo that math — and do it again every year, because the proposal builds in annual inflation and growth adjustments. Watch for earnings calls in the next two quarters where CFOs quietly revise capital return targets and buyback guidance downward. Banks will likely push back hard during the comment period, arguing the new coefficients overstate systemic risk. Expect lobbying focused on the short-term wholesale funding changes, which directly constrain a profitable corner of bank balance sheets.

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The Sendoff
The Federal Reserve has proposed that megabanks hold more capital and that the formula adjusts automatically every year going forward. The banks will be submitting comments.