It’s fair to say that last Thursday’s “Basel III endgame” proposal by the U.S. banking regulators probably ruined a lot of summer vacations, with its 1,000-page reading assignment.

As we all know, this is a major development, and it is putting banks and their advisors – including law firms like ours – to work this summer to assess the new proposal and to advise on next steps. As my colleagues Jed Miller, Ivan Loncar and I note in our lead article this week, our phones have been ringing and our email accounts have been very active, as we have been reaching out to our banking clients and responding to incoming inquiries.

We hope you’ll read our article focused on the securitizations and risk transfer implications in the proposal and, remember, we’re definitely here to help. You can reach out to us here.

Daniel Meade 
Partner and Editor, Cabinet News and Views

On July 27, 2023, the U.S. federal prudential bank regulators (the Federal Deposit Insurance Corporation, the Federal Reserve Board and the Office of the Comptroller of the Currency) proposed new capital requirements for large banking organizations. The FRB also proposed to make certain adjustments to the G-SIB surcharge. Over the last week, we’ve received a number of inquiries from banks and buy-side clients about this proposal – in particular, about its effect on banks’ risk-based capital, including for fund finance transactions, and capital optimization strategies, such as capital relief trades and synthetic securitizations.

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This Clients & Friends Memo considers the rules proposed by the UK’s Prudential Regulation Authority to replace retained EU law and technical standards governing securitisations. Our analysis also covers the rules’ changes to risk retention and disclosure technical standards, and notes contrasts with the recently published final form EU technical standards.

You may access the Memo here.