Basel 3 Endgame and G-SIB NPR Response
The objective of this study was to provide the analytical basis for an industry response to the Basel 3 Endgame implementation roadmap outlined in two Notices of Proposed Rulemaking (NPR) covering risk-based capital requirements and the G-SIB surcharge.
Each of the 8 U.S. G-SIBs provided various slices of their year-end 2025 exposure data for the banking book and the trading book.
Study results were used to benchmark the expected capital impact using industry data against the -4.8% combined impact announced by the Federal Reserve on March 19.
The study concluded successfully with GARP's analysis written into an official comment letter posted by the Financial Services Forum, Bank Policy Institute, the American Bankers Association, the U.S. Chamber of Commerce, and the Consumer Bankers Association.

