Cleary Gottlieb Discusses Proposed Capital-Requirement Increases for Banks
Reynolds Holding
JULY 31, 2023
The banking agencies do not anticipate making a final rule effective until at least July 2025, and the proposal suggests a three-year phase-in period after that for most provisions. Risks would be required to be modeled (and internal models approved and backtested) at the level of individual trading desks rather than at the firm level.
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