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There would be no change in the capital framework for smaller firms, except that those firms with significant trading activities would be subject to the market-risk capital provisions. This new approach would include standardized risk-weights for credit, equity, operational, and credit valuation adjustment risk.
Further, while US regulators initially signaled that capital levels would not be materially impacted by the Endgame Standard, the Capital Proposal is now expected to increase common equity Tier 1 (“CET1”) capital by around 16% for banking organizations subject to the Capital Proposal.
Of most importance for financial institutions, the identified categories also include downstream activities such as “investments” (Category 15 of the GHG Protocol’s Scope 3 emissions categories), which would capture financed emissions ( i.e. , emissions from companies to which the financial institution provides debt or equity financing).
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