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Cleary Gottlieb Discusses Proposed Capital-Requirement Increases for Banks

Reynolds Holding

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.

Banking 40
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Sullivan & Cromwell Discusses the Implications for Financial Institutions of Proposed SEC Climate Disclosure Rules

Reynolds Holding

In particular, the disclosure of Scope 3 greenhouse gas emissions (which capture financed emissions) and climate scenario analysis will likely be mandatory for many financial institutions. Compliance with the proposed rules would be phased in (see Appendix A for disclosure compliance dates). Scope 3 GHG Emissions.

Finance 45
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Mayer Brown Discusses Bank Regulators’ Proposed Overhaul of Capital Requirements

Reynolds Holding

Require these banking organizations to calculate their risk-based capital ratios under the existing standardized approach and expanded standardized approach (a “dual-stack” requirement), and use the lower (less favorable) ratio of the two. Eliminate the opt-out for accumulated other comprehensive income (“AOCI”).

Banking 52