- Since mid-2025, the Fed has shifted toward deregulation, easing capital rules and emphasizing supervision of material financial risks over procedural compliance.
- A final rule issued Nov. 25, 2025 cuts the enhanced supplementary leverage ratio for the largest banks, effective April 1, 2026, reducing capital costs for low-risk assets like U.S. Treasuries.
- New supervisory guidance deemphasizes reputational risk and documentation, expands bank self-certification, and coincides with a roughly 30% staffing reduction via attrition.
- Broader political moves, including a renewed FSOC mandate under Treasury Secretary Scott Bessent, aim to cut duplicative regulation while critics warn of weaker crisis resilience.
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In late 2025, the Fed has charted a notable shift in financial regulation that materially eases constraints imposed after the 2008 crisis. Among the most consequential is the easing of the Enhanced Supplementary Leverage Ratio (eSLR) for large, systemically important banking organizations. Under the new final rule issued November 25, 2025, these banks and their depository subsidiaries are permitted to reduce certain leverage capital requirements—cutting the eSLR at the holding company level to range between 3.5%–4.5% (from 5%), with subsidiaries also brought into this range (from 6%)—while still serving as a backstop to risk-based capital requirements.[0search0][0news16]
This capital rule change is intended to reduce the disincentives banks face when holding low-risk assets, like U.S. Treasuries, that form essential parts of the Treasury market’s functionality. Proponents argue this aids market liquidity and reduces demands for government intervention during stress. Critics, including Fed Governor Michael Barr and Adriana Kugler, warn it may reduce banks’ cushion in crisis scenarios and shift risk to the Deposit Insurance Fund. [0search0]
Alongside capital relief, supervisory philosophy is shifting. New guidelines released in November 2025 direct examiners to focus on material financial risks—unsound business practices, asset quality, and balance sheet exposures—while de-emphasizing process-oriented oversight, reputational risk assessments, and documentation burdens. This comes with a roughly 30% cut in regulatory staff via attrition. These changes are championed by the industry, seen as long-sought after simplifications, though dissenters argue it may weaken early detection of emerging risks.
Politically, regulatory change is being reinforced through broader institutional shifts. Treasury Secretary Scott Bessent has repositioned FSOC to spotlight regulatory burden reduction, address overlaps, and integrate oversight of emerging sectors like AI. These moves align with the Trump administration’s deregulatory agenda. Powerful Republicans support the adjustments; progressive critics like Sen. Warren warn they could increase systemic fragility.
Strategic implications for banks and investors are multifold. Large banks stand to improve returns on low-risk asset holdings and reduce capital carry costs. Treasury market liquidity may strengthen, assuming banks reinvest freed capital. However, with supervision staff reductions and lighter oversight in some domains, risk modeling assumptions may fail to capture adverse shocks – particularly around subsidiaries, housing, or consumer finance sectors. Open questions remain around how quickly and comprehensively these rules will be adopted, how they impact non-bank players, whether international regulatory harmonization (e.g. Basel) pressures will reassert, and how rating agencies and markets respond to shifts in risk posture.
Supporting Notes
- Final rule modifying regulatory capital standards was issued on November 25, 2025, effective April 1, 2026, allowing banks to elect adoption as early as January 1, 2026.
- The eSLR reduction lowers holding companies’ capital requirement by ~1.4%, particularly impacting large globally systemically important bank holding companies (G-SIBs). [0search0][0news16]
- Depository institution subsidiaries will also benefit from lower leverage ratio caps, capped so that their eSLR does not exceed 4%.
- New supervisory guidelines released November 18, 2025 prioritize material financial risks, deprioritize documentation and reputational risk, and allow some self-certification by banks.
- A 30% reduction in regulatory staff under Vice Chair for Supervision Michelle Bowman has been announced, mostly via attrition.
- Treasury Secretary Scott Bessent’s letter and FSOC report (December 2025) advocate for the reduction of duplicative regulation and regulatory burdens, with new priorities including AI and crisis preparedness.
