Focus: Wall Street banks plan final push on capital rules

• Banks are targeting a new requirement to hold capital against 10% of unused credit card lines (nearly $5 trillion in unused lines existed at end of 2025), arguing it could force them to reduce credit limits and cancel unused lines, though regional banks would be exempt under simpler rules.
• Major banks want the GSIB surcharge recalculated using 2015 baseline data adjusted for economic growth rather than the Fed's proposed recent-only adjustment, which could significantly reduce their capital surcharges.
• JPMorgan Chase expects its capital requirements to actually increase under current proposals while competitors' requirements fall, creating uneven impacts despite the overall 4.8% reduction in industry capital requirements.

Summary: Wall Street Banks Seek Final Relief on Basel Capital Rules

Major U.S. banks are making a final push to reduce capital requirements under revised Basel rules before the November election, according to industry sources. The Federal Reserve's March proposal would reduce capital buffers by approximately 4.8%—far less than the original 2023 plan's 20% increase—but banks are seeking additional relief.

Key Issues:

Banks are targeting two main areas:

1. Credit card lines: The proposal requires holding capital against 10% of unused credit lines, affecting nearly $5 trillion in unused credit card capacity. Currently these lines carry no capital charge since banks can cancel them anytime. Industry warns this could force credit limit cuts. Regional banks are exempt under a simpler regime.

1. GSIB surcharge: Globally systemically important banks want the Fed to recalculate their capital surcharges using 2015 baseline data to account for economic growth, which could significantly reduce requirements. The Fed proposed only adjusting from recent years forward.

Major Players:

JPMorgan Chase, Wells Fargo, Citigroup, and Bank of America are leading the effort through trade groups. JPMorgan CEO Jamie Dimon stated his bank's capital will actually increase under current proposals while competitors' decreases, calling aspects "nonsensical."

Timeline & Politics:

Fed Vice Chair Michelle Bowman aims to finalize rules by year-end. Banks want completion before November mid-term elections, which could shift power to Democrats less sympathetic to industry concerns. Bowman has urged banks to avoid aggressive lobbying tactics used against the 2023 proposal.

Bank Policy Institute CEO Greg Baer indicated the industry will submit extensive feedback before next month's deadline, recognizing this may be their most favorable regulatory environment for years.