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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

Compliance with the proposed rules would be phased in (see Appendix A for disclosure compliance dates). The proposed rules, if adopted as proposed, would have particularly significant ramifications on the cost and complexity of SEC compliance for financial institutions because of their financed emissions. filed in 2025).

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. About 40 banking organizations currently are subject to the market risk capital requirement.

Banking 52