DEPARTMENT OF THE TREASURY, OFFICE OF THE COMPTROLLER OF THE CURRENCY; FEDERAL RESERVE SYSTEM; FEDERAL DEPOSIT INSURANCE CORPORATION: REGULATORY CAPITAL RULE: MODIFICATIONS TO THE ENHANCED SUPPLEMENTARY LEVERAGE RATIO STANDARDS FOR U.S. GLOBAL SYSTEMICALLY IMPORTANT BANK HOLDING COMPANIES AND THEIR SUBSIDIARY DEPOSITORY INSTITUTIONS; TOTAL LOSS-ABSORBING CAPACITY AND LONG-TERM DEBT REQUIREMENTS FO

The following information was released by the U.S. Government Accountability Office (GAO):

Highlights

GAO reviewed the Department of the Treasury, Office of the Comptroller of the Currency (OCC); the Board of Governors of the Federal Reserve System (Board); and the Federal Deposit Insurance Corporation's (FDIC) (collectively, the Agencies) new rule entitled "Regulatory Capital Rule: Modifications to the Enhanced Supplementary Leverage Ratio Standards for U.S. Global Systemically Important Bank Holding Companies and Their Subsidiary Depository Institutions; Total Loss-Absorbing Capacity and Long-Term Debt Requirements for U.S. Global Systemically Important Bank Holding Companies." GAO found that the final rule (1) modifies the enhanced supplementary leverage ratio standards applicable to U.S. bank holding companies identified as global systemically important bank holding companies (GSIBs), their subsidiary depository institutions that are Board or FDIC-regulated, and national banks and Federal savings associations that are subsidiaries of a U.S. top-tier bank holding company with total consolidated assets of more than $700 billion or assets under custody of more than $10 trillion; and (2) finalizes conforming amendments to the Board's total loss-absorbing capacity and long-term debt requirements.

Enclosed is our assessment of the Agencies' compliance with the procedural steps required by section 801(a)(1)(B)(i) through (iv) of title 5 with respect to the rule. If you have any questions about this report or wish to contact GAO officials responsible for the evaluation work relating to the subject matter of the rule, please contact me at (202) 512-8156.

The Honorable Tim Scott

Chairman

The Honorable Elizabeth Warren

Ranking Member

Committee on Banking, Housing, and Urban Affairs

United States Senate

The Honorable French Hill

Chairman

The Honorable Maxine Waters

Ranking Member

Committee on Financial Services House of Representatives

Subject: Department of the Treasury, Office of the Comptroller of the Currency; Federal Reserve System; Federal Deposit Insurance Corporation: Regulatory Capital Rule: Modifications to the Enhanced Supplementary Leverage Ratio Standards for U.S. Global Systemically Important Bank Holding Companies and Their Subsidiary Depository Institutions; Total Loss-Absorbing Capacity and Long-Term Debt Requirements for U.S. Global Systemically Important Bank Holding Companies

Pursuant to section 801(a)(2)(A) of title 5, United States Code, this is our report on a major rule promulgated by the Department of the Treasury, Office of the Comptroller of the Currency (OCC); the Board of Governors of the Federal Reserve System (Board); and the Federal Deposit Insurance Corporation (FDIC) (collectively, the Agencies) entitled "Regulatory Capital Rule: Modifications to the Enhanced Supplementary Leverage Ratio Standards for U.S. Global Systemically Important Bank Holding Companies and Their Subsidiary Depository Institutions; Total Loss-Absorbing Capacity and Long-Term Debt Requirements for U.S. Global Systemically Important Bank Holding Companies" (RINs: 1557-AF31, 7100-AG96, 3064-AG11). Wereceived the rule from OCC on December 17, 2025, and from FDIC on December 22, 2025. It was published in the Federal Register on December 1, 2025. 90 Fed. Reg. 55248. The effective date of the rule is April 1, 2026.

According to the Agencies, this rule modifies the enhanced supplementary leverage ratio standards applicable to U.S. bank holding companies identified as global systemically important bank holding companies (GSIBs), their subsidiary depository institutions that are Board or FDIC-regulated, and national banks and Federal savings associations that are subsidiaries of a U.S. top-tier bank holding company with total consolidated assets of more than $700 billion or assets under custody of more than $10 trillion. Additionally, the rule finalizes conforming amendments to the Board's total loss-absorbing capacity and long-term debt requirements.

Enclosed is our assessment of the Agencies' compliance with the procedural steps required by section801(a)(1)(B)(i) through (iv) of title 5 with respect to the rule. If you have any questions about this report or wish to contact GAO officials responsible for the evaluation work relating to the subject matter of the rule, please contact me at (202) 512-8156.

Shirley A. Jones

Managing Associate General Counsel

Enclosure

cc: Carl Kaminski

Assistant Director, Bank Advisory Group, Chief Counsel's Office

Office of the Comptroller of the Currency

M. Andy Jiminez

Director, Office of Legislative Affairs

Federal Deposit Insurance Corporation

ENCLOSURE

REPORT UNDER 5 U.S.C. 801(a)(2)(A) ON A MAJOR RULE

ISSUED BY THE

DEPARTMENT OF THE TREASURY,

OFFICE OF THE COMPTROLLER OF THE CURRENCY;

FEDERAL RESERVE SYSTEM;

FEDERAL DEPOSIT INSURANCE CORPORATION

ENTITLED

"REGULATORY CAPITAL RULE: MODIFICATIONS TO THE ENHANCED SUPPLEMENTARY LEVERAGE RATIO STANDARDS FOR U.S. GLOBAL SYSTEMICALLY IMPORTANT BANK HOLDING COMPANIES AND THEIR SUBSIDIARY DEPOSITORY INSTITUTIONS;

TOTAL LOSS-ABSORBING CAPACITY AND LONG-TERM DEBT REQUIREMENTS

FOR U.S. GLOBAL SYSTEMICALLY IMPORTANT BANK HOLDING COMPANIES"

(RINS: 1557-AF31, 7100-AG96, 3064-AG11)

(i) Cost-benefit analysis

The Department of the Treasury, Office of the Comptroller of the Currency (OCC); the Board of Governors of the Federal Reserve System; and the Federal Deposit Insurance Corporation (collectively, the Agencies) prepared an analysis of the costs and benefits for this rule. The Agencies anticipate the economic costs resulting from the rule to be negligible because tier 1 capital requirements for specified organizations will remain essentially unchanged. Additionally, the Agencies expect that the rule will (1) reduce unintended disincentives for specified banking organizations to engage in low-risk activities as well as unintended incentives to engage in higher-risk activities; and (2) enhance the functioning of financial markets, including the U.S. Treasury market, by creating additional capacity for global systemically important bank holding companies to engage in market intermediation. 90 Fed. Reg. 55248, 55272, 55276 (Dec. 1, 2025).

(ii) Agency actions relevant to the Regulatory Flexibility Act (RFA), 5 U.S.C. 603605, 607, and 609

The Agencies certified that this rule will not have a significant economic impact on a substantial number of small entities. 90 Fed. Reg. 5528555286.

(iii) Agency actions relevant to sections 202205 of the Unfunded Mandates Reform Act of 1995, 2 U.S.C. 15321535

OCC determined that this rule will not result in the expenditure by state, local, or tribal governments, in the aggregate, or by the private sector, of $100 million or more in any one year. 90 Fed. Reg. 55286.

(iv) Other relevant information or requirements under acts and executive orders

Administrative Procedure Act, 5 U.S.C. 551 et seq.

On July 10, 2025, the Agencies published a proposed rule. 90 Fed. Reg. 30780. The Agencies received approximately 40 comments on the proposal from a range of parties including policy advocacy groups, banking organizations, banking and financial industry trade associations, other financial market participants, academics, Members of Congress, research organizations, and individuals. 90 Fed. Reg. 55251. The Agencies summarized and responded to comments in the rule. 90 Fed. Reg. 5525155252.

Paperwork Reduction Act (PRA), 44 U.S.C. 35013520

The Agencies determined that this rule contains revisions and an extension to an information collection requirement previously submitted to the Office of Management and Budget (OMB No. 7100-0128). 90 Fed. Reg. 55284.

Statutory authorization for the rule

The Agencies promulgated this rule pursuant to sections 93a, 161, 1462, 1462a, 1463, 1464, 1818, 1828(n), 1828 note, 1831n note, 1835, 3907, 3909, and 5412(b)(2)(B) of title 12, United States Code; and Public Law 116-136, 134 Stat. 281.

Executive Order No. 12866 (Regulatory Planning and Review)

The Agencies stated that the Office of Information and Regulatory Affairs has determined that this rule is a significant regulatory action under the Order. 90 Fed. Reg. 55286.

Executive Order No. 13132 (Federalism)

In its submission to us, the Agencies indicated that the Order is not applicable to this rule.