| Regulation and Capital Adequacy |
Regulation and Capital Adequacy The FRB is the primary regulator of Group Inc., a BHC under the U.S. Bank Holding Company Act of 1956 and a financial holding company under amendments to this Act. The firm is subject to consolidated regulatory capital requirements which are calculated in accordance with the regulations of the FRB (Capital Framework). The capital requirements are expressed as risk-based capital and leverage ratios that compare measures of regulatory capital to risk-weighted assets (RWAs), average assets and off-balance sheet exposures. Failure to comply with these capital requirements could result in restrictions being imposed by the firm’s regulators and could limit the firm’s ability to repurchase shares, pay dividends and make certain discretionary compensation payments. The firm’s capital levels are also subject to qualitative judgments by the regulators about components of capital, risk weightings and other factors. Furthermore, certain of the firm’s subsidiaries are subject to separate regulations and capital requirements. The regulations under the Capital Framework are largely based on the Basel Committee on Banking Supervision’s (Basel Committee) capital framework for strengthening international capital standards (Basel III) and also implement certain provisions of the Dodd-Frank Act. Under the Capital Framework, the firm is an “Advanced approach” banking organization and has been designated as a global systemically important bank (G-SIB). The Capital Framework includes the minimum risk-based capital and the capital conservation buffer requirements. The buffer must consist entirely of capital that qualifies as Common Equity Tier 1 (CET1) capital. The firm calculates its CET1 capital, Tier 1 capital and Total capital ratios in accordance with both the Standardized and Advanced Capital Rules. Each of the ratios calculated under the Standardized and Advanced Capital Rules must meet its respective capital requirements. Under the Capital Framework, the firm is also subject to leverage requirements which consist of a minimum Tier 1 leverage ratio and a minimum supplementary leverage ratio (SLR), as well as the SLR buffer. Consolidated Regulatory Capital Requirements Risk-Based Capital Ratios. The table below presents the risk-based capital requirements as of both September 2021 and December 2020.
|
|
|
|
|
|
|
|
|
| |
|
|
|
|
|
Standardized |
|
|
|
Advanced |
|
CET1 capital ratio |
|
|
13.6% |
|
|
|
9.5% |
|
Tier 1 capital ratio |
|
|
15.1% |
|
|
|
11.0% |
|
Total capital ratio |
|
|
17.1% |
|
|
|
13.0% |
| In the table above:
| • |
|
Under both the Standardized and Advanced Capital Rules, the CET1 capital ratio requirement includes a minimum of 4.5%, the Tier 1 capital ratio requirement includes a minimum of 6.0% and the Total capital ratio requirement includes a minimum of 8.0%. These requirements also include the capital conservation buffer requirements, consisting of the G-SIB surcharge of 2.5% (Method 2) and the countercyclical capital buffer, which the FRB has set to zero percent. In addition, the capital conservation buffer requirements include the stress capital buffer (SCB) of 6.6% under the Standardized Capital Rules and a buffer of 2.5% under the Advanced Capital Rules. |
| • |
|
The G-SIB surcharge is updated annually based on financial data from the prior year and is generally applicable for the following year. The G-SIB surcharge is calculated using two methodologies, the higher of which is reflected in the firm’s risk-based capital requirements. The first calculation (Method 1) is based on the Basel Committee’s methodology which, among other factors, relies upon measures of the size, activity and complexity of each G-SIB. The second calculation (Method 2) uses similar inputs but includes a measure of reliance on short-term wholesale funding. | Based on the firm’s 2021 Comprehensive Capital Analysis and Review submission, the FRB has set the SCB for the firm at 6.4% for the period from October 1, 2021 through September 30, 2022. As a result, beginning on October 1, 2021, the firm’s Standardized requirements are 13.4% for the CET1 capital ratio, 14.9% for the Tier 1 capital ratio and 16.9% for the Total capital ratio. The table below presents information about risk-based capital ratios.
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|
|
|
|
|
|
| |
|
|
|
|
|
Standardized |
|
|
|
Advanced |
|
|
|
|
|
|
|
|
|
|
CET1 capital |
|
|
|
|
|
|
|
|
Tier 1 capital |
|
|
|
|
|
|
|
|
Tier 2 capital |
|
|
|
|
|
|
|
|
Total capital |
|
|
|
|
|
|
|
|
RWAs |
|
|
|
|
|
|
|
|
CET1 capital ratio |
|
|
|
|
|
|
|
|
Tier 1 capital ratio |
|
|
|
|
|
|
|
|
Total capital ratio |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
CET1 capital |
|
|
$ 81,641 |
|
|
|
$ 81,641 |
|
Tier 1 capital |
|
|
$ 92,730 |
|
|
|
$ 92,730 |
|
Tier 2 capital |
|
|
$ 15,424 |
|
|
|
$ 13,279 |
|
Total capital |
|
|
$108,154 |
|
|
|
$106,009 |
|
RWAs |
|
|
$554,162 |
|
|
|
$609,750 |
|
CET1 capital ratio |
|
|
14.7% |
|
|
|
13.4% |
|
Tier 1 capital ratio |
|
|
16.7% |
|
|
|
15.2% |
|
Total capital ratio |
|
|
19.5% |
|
|
|
17.4% |
| s permitted by the FRB, the firm elected to temporarily delay the estimated effects of adopting CECL on regulatory capital until January 2022 and to subsequently phase-in the effects through January 2025. In addition, the firm elected to increase regulatory capital by 25% of the increase in the allowance for credit losses since January 1, 2020, as permitted by the rules issued by the FRB. The impact of this increase will also be phased in over the three-year transition period. Reflecting the full impact of CECL as of both September 2021 and December 2020 would not have had a material impact on the firm’s capital ratios. In the third quarter of 2021, based on regulatory feedback, the firm revised certain interpretations of the Capital Rules underlying the calculation of Standardized RWAs. These revisions were reflected in the firm’s capital ratios as of September 2021 and increased the firm’s Standardized RWAs by approximately $23 billion and reduced both the firm’s Standardized CET1 and Standardized Tier 1 capital ratios by 0.5 percentage points, and Standardized Total capital ratio by 0.7 percentage points as of September 2021. The following provides information about the impact of the RWA changes on prior periods:
• |
|
As of June 2021, this change would have increased the firm’s Standardized RWAs of $621 billion by approximately $23 billion, which would have reduced the firm’s Standardized CET1 capital ratio of 14.4% by 0.5 percentage points, Standardized Tier 1 capital ratio of 15.9% by 0.6 percentage points and Standardized Total capital ratio of 18.3% by 0.7 percentage points. |
• |
|
As of March 2021, this change would have increased the firm’s Standardized RWAs of $595 billion by approximately $22 billion, which would have reduced the firm’s Standardized CET1 capital ratio of 14.3% by 0.5 percentage points, Standardized Tier 1 capital ratio of 15.9% by 0.6 percentage points and Standardized Total capital ratio of 18.4% by 0.7 percentage points. |
• |
|
As of December 2020, this change would have increased the firm’s Standardized RWAs of $554 billion by approximately $23 billion, which would have reduced the firm’s Standardized CET1 ratio of 14.7% by 0.6 percentage points, Standardized Tier 1 capital ratio of 16.7% by 0.6 percentage points and Standardized Total capital ratio of 19.5% by 0.8 percentage points. |
• |
|
As of September 2020, this change would have increased the firm’s Standardized RWAs of $535 billion by approximately $20 billion, which would have reduced the firm’s Standardized CET1 capital ratio of 14.5% by 0.5 percentage points, Standardized Tier 1 capital ratio of 16.6% by 0.6 percentage points and Standardized Total capital ratio of 19.6% by 0.7 percentage points. | The table below presents the leverage requirements.
|
|
|
|
|
| |
|
|
|
|
|
|
Tier 1 leverage ratio |
|
|
|
|
SLR |
|
|
|
| In the table above, the SLR requirement of 5% includes a minimum of 3% and a 2% buffer applicable to G-SIBs. The table below presents information about leverage ratios.
|
|
|
|
|
|
|
|
|
| |
|
| |
|
For the Three Months Ended or as of |
|
| |
|
|
|
|
|
|
|
|
|
December 2020 |
|
|
|
|
|
|
|
|
$ 92,730 |
|
Average total assets |
|
|
|
|
|
|
$1,152,785 |
|
Deductions from Tier 1 capital |
|
|
|
|
|
|
(4,948 |
) |
Average adjusted total assets |
|
|
|
|
|
|
1,147,837 |
|
Impact of SLR temporary amendment |
|
|
|
|
|
|
(202,748 |
) |
Average off-balance sheet exposures |
|
|
|
|
|
|
387,848 |
|
|
|
|
|
|
|
|
$1,332,937 |
|
|
|
|
|
|
|
|
8.1% |
|
|
|
|
|
|
|
|
7.0% |
| In the table above:
| • |
|
Average total assets represents the average daily assets for the quarter adjusted for the impact of CECL transition. |
| • |
|
Impact of SLR temporary amendment represented the exclusion of average holdings of U.S. Treasury securities and average deposits at the Federal Reserve as permitted by the FRB. The impact of this temporary amendment was an increase in the firm’s SLR by approximately 1.0 percentage points for the three months ended December 2020. The amendment permitting this exclusion expired on April 1, 2021. |
| • |
|
Average off-balance sheet exposures represents the monthly average and consists of derivatives, securities financing transactions, commitments and guarantees. |
| • |
|
Tier 1 leverage ratio is calculated as Tier 1 capital divided by average adjusted total assets. |
| • |
|
SLR is calculated as Tier 1 capital divided by total leverage exposure. | The table below presents information about risk-based capital.
|
|
|
|
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|
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|
| |
|
| |
|
As of |
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| |
|
|
|
|
|
|
|
|
|
December 2020 |
|
Common shareholders’ equity |
|
|
|
|
|
|
$ 84,729 |
|
Impact of CECL transition |
|
|
|
|
|
|
1,126 |
|
Deduction for goodwill |
|
|
|
|
|
|
(3,652 |
) |
Deduction for identifiable intangible assets |
|
|
|
|
|
|
(601 |
) |
Other adjustments |
|
|
|
|
|
|
39 |
|
|
|
|
|
|
|
|
81,641 |
|
Preferred stock |
|
|
|
|
|
|
11,203 |
|
Deduction for investments in covered funds |
|
|
|
|
|
|
(106 |
) |
Other adjustments |
|
|
|
|
|
|
(8 |
) |
|
|
|
|
|
|
|
$ 92,730 |
|
Standardized Tier 2 and Total capital |
|
|
|
|
|
|
|
|
Tier 1 capital |
|
|
|
|
|
|
$ 92,730 |
|
Qualifying subordinated debt |
|
|
|
|
|
|
12,196 |
|
Junior subordinated debt |
|
|
|
|
|
|
188 |
|
Allowance for credit losses |
|
|
|
|
|
|
3,095 |
|
Other adjustments |
|
|
|
|
|
|
(55 |
) |
Standardized Tier 2 capital |
|
|
|
|
|
|
15,424 |
|
Standardized Total capital |
|
|
|
|
|
|
$108,154 |
|
Advanced Tier 2 and Total capital |
|
|
|
|
|
|
|
|
Tier 1 capital |
|
|
|
|
|
|
$ 92,730 |
|
Standardized Tier 2 capital |
|
|
|
|
|
|
15,424 |
|
Allowance for credit losses |
|
|
|
|
|
|
(3,095 |
) |
Other adjustments |
|
|
|
|
|
|
950 |
|
Advanced Tier 2 capital |
|
|
|
|
|
|
13,279 |
|
|
|
|
|
|
|
|
$106,009 |
| In the table above:
| • |
|
Impact of CECL transition represents the impact of adoption as of January 1, 2020 and the impact of increasing regulatory capital by 25% of the increase in the allowance for credit losses since January 1, 2020. The allowance for credit losses within Standardized and Advanced Tier 2 capital also reflects the impact of these adjustments. |
| • |
|
Deduction for goodwill was net of deferred tax liabilities of $674 million as of September 2021 and $680 million as of December 2020. |
| • |
|
Deduction for identifiable intangible assets was net of deferred tax liabilities of $19 million as of September 2021 and $29 million as of December 2020. |
| • |
|
Deduction for investments in covered funds represents the firm’s aggregate investments in applicable covered funds, excluding investments that are subject to an extended conformance period. See Note 8 for further information about the Volcker Rule. |
| • |
|
Other adjustments within CET1 capital and Tier 1 capital primarily include credit valuation adjustments on derivative liabilities, the overfunded portion of the firm’s defined benefit pension plan obligation net of associated deferred tax liabilities, disallowed deferred tax assets, debt valuation adjustments and other required credit risk-based deductions. Other adjustments within Advanced Tier 2 capital include eligible credit reserves. |
| • |
|
Qualifying subordinated debt is subordinated debt issued by Group Inc. with an original maturity of five years or greater. The outstanding amount of subordinated debt qualifying for Tier 2 capital is reduced upon reaching a remaining maturity of five years. See Note 14 for further information about the firm’s subordinated debt. |
| • |
|
Junior subordinated debt is debt issued to a Trust. As of September 2021, 10% of this debt was included in Tier 2 capital and 90% was phased out of regulatory capital. As of December 2020, 20% of this debt was included in Tier 2 capital and 80% was phased out of regulatory capital. Junior subordinated debt is reduced by the amount of Trust Preferred securities purchased by the firm and will be fully phased out of Tier 2 capital by 2022. See Note 14 for further information about the firm’s junior subordinated debt and Trust Preferred securities. | The table below presents changes in CET1 capital, Tier 1 capital and Tier 2 capital.
|
|
|
|
|
|
|
|
|
| |
|
|
|
|
|
Standardized |
|
|
|
Advanced |
|
Nine Months Ended September 2021 |
|
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|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
Beginning balance |
|
|
|
|
|
|
|
|
Change in: |
|
|
|
|
|
|
|
|
Common shareholders’ equity |
|
|
|
|
|
|
|
|
Impact of CECL transition |
|
|
|
|
|
|
|
|
Deduction for identifiable intangible assets |
|
|
|
|
|
|
|
|
Other adjustments |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
Beginning balance |
|
|
|
|
|
|
|
|
Change in: |
|
|
|
|
|
|
|
|
CET1 capital |
|
|
|
|
|
|
|
|
Deduction for investments in covered funds |
|
|
|
|
|
|
|
|
Preferred stock |
|
|
|
|
|
|
|
|
Other adjustments |
|
|
|
|
|
|
|
|
Ending balance |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
Beginning balance |
|
|
|
|
|
|
|
|
Change in: |
|
|
|
|
|
|
|
|
Qualifying subordinated debt |
|
|
|
|
|
|
|
|
Junior subordinated debt |
|
|
|
|
|
|
|
|
Allowance for credit losses |
|
|
|
|
|
|
|
|
Other adjustments |
|
|
|
|
|
|
|
|
Ending balance |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
Beginning balance |
|
|
$ 74,850 |
|
|
|
$ 74,850 |
|
Change in: |
|
|
|
|
|
|
|
|
Common shareholders’ equity |
|
|
5,667 |
|
|
|
5,667 |
|
Impact of CECL transition |
|
|
1,126 |
|
|
|
1,126 |
|
Deduction for goodwill |
|
|
(123 |
) |
|
|
(123 |
) |
Deduction for identifiable intangible assets |
|
|
3 |
|
|
|
3 |
|
Other adjustments |
|
|
118 |
|
|
|
118 |
|
Ending balance |
|
|
$ 81,641 |
|
|
|
$ 81,641 |
|
|
|
|
|
|
|
|
|
|
Beginning balance |
|
|
$ 85,440 |
|
|
|
$ 85,440 |
|
Change in: |
|
|
|
|
|
|
|
|
CET1 capital |
|
|
6,791 |
|
|
|
6,791 |
|
Deduction for investments in covered funds |
|
|
504 |
|
|
|
504 |
|
Other adjustments |
|
|
(5 |
) |
|
|
(5 |
) |
Ending balance |
|
|
92,730 |
|
|
|
92,730 |
|
|
|
|
|
|
|
|
|
|
Beginning balance |
|
|
14,925 |
|
|
|
13,473 |
|
Change in: |
|
|
|
|
|
|
|
|
Qualifying subordinated debt |
|
|
(651 |
) |
|
|
(651 |
) |
Junior subordinated debt |
|
|
(96 |
) |
|
|
(96 |
) |
Allowance for credit losses |
|
|
1,293 |
|
|
|
– |
|
Other adjustments |
|
|
(47 |
) |
|
|
553 |
|
Ending balance |
|
|
15,424 |
|
|
|
13,279 |
|
Total capital |
|
|
$108,154 |
|
|
|
$106,009 |
| RWAs are calculated in accordance with both the Standardized and Advanced Capital Rules. Credit RWAs are calculated based on measures of exposure, which are then risk weighted under the Standardized and Advanced Capital Rules:
| • |
|
The Standardized Capital Rules apply prescribed risk-weights, which depend largely on the type of counterparty. The exposure measure for derivatives and securities financing transactions are based on specific formulas which take certain factors into consideration. |
| • |
|
Under the Advanced Capital Rules, the firm computes risk-weights for wholesale and retail credit exposures in accordance with the Advanced Internal Ratings-Based approach. The exposure measures for derivatives and securities financing transactions are computed utilizing internal models. |
| • |
|
For both Standardized and Advanced credit RWAs, the risk-weights for securitizations and equities are based on specific required formulaic approaches. | RWAs for market risk in accordance with the Standardized and Advanced Capital Rules are generally consistent. Market RWAs are calculated based on measures of exposure which include the following:
| • |
|
(VaR) is the potential loss in value of trading assets and liabilities, as well as certain investments, loans, and other financial assets and liabilities accounted for at fair value, due to adverse market movements over a defined time horizon with a specified confidence level. | For both risk management purposes and regulatory capital calculations, the firm uses a single VaR model which captures risks, including those related to interest rates, equity prices, currency rates and commodity prices. However, VaR used for risk management purposes differs from VaR used for regulatory capital requirements (regulatory VaR) due to differences in time horizons, confidence levels and the scope of positions on which VaR is calculated. For risk management purposes, a 95% one-day VaR is used, whereas for regulatory capital requirements, a 99% 10-day VaR is used to determine Market RWAs and a 99% one-day VaR is used to determine regulatory VaR exceptions. In addition, the daily net revenues used to determine risk management VaR exceptions (i.e., comparing the daily net revenues to the VaR measure calculated as of the end of the prior business day) include intraday activity, whereas the Capital Framework requires that intraday activity be excluded from daily net revenues when calculating regulatory VaR exceptions. Intraday activity includes bid/offer net revenues, which are more likely than not to be positive by their nature. As a result, there may be differences in the number of VaR exceptions and the amount of daily net revenues calculated for regulatory VaR compared to the amounts calculated for risk management VaR. The firm’s positional losses observed on a single day did not exceed its 99% one-day regulatory VaR during the nine months ended September 2021 and exceeded its 99 one-day regulatory VaR on six occasions during 2020 (all of which occurred during March 2020 and, as permitted by the FRB, did not have any impact on the firm’s VaR multiplier used to calculate Market RWAs);
• |
|
Stressed VaR is the potential loss in value of trading assets and liabilities, as well as certain investments, loans, and other financial assets and liabilities accounted for at fair value, during a period of significant market stress; |
• |
|
Incremental risk is the potential loss in value of non-securitized positions due to the default or credit migration of issuers of financial instruments over a one-year time horizon; |
• |
|
Comprehensive risk is the potential loss in value, due to price risk and defaults, within the firm’s credit correlation positions; and |
• |
|
Specific risk is the risk of loss on a position that could result from factors other than broad market movements, including event risk, default risk and idiosyncratic risk. The standardized measurement method is used to determine specific risk RWAs, by applying supervisory defined risk-weighting factors after applicable netting is performed. | Operational RWAs are only required to be included under the Advanced Capital Rules. The firm utilizes an internal risk-based model to quantify Operational RWAs. The table below presents information about RWAs.
|
|
|
|
|
|
|
|
|
| |
|
|
|
|
|
Standardized |
|
|
|
Advanced |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
Derivatives |
|
|
|
|
|
|
|
|
Commitments, guarantees and loans |
|
|
|
|
|
|
|
|
Securities financing transactions |
|
|
|
|
|
|
|
|
Equity investments |
|
|
|
|
|
|
|
|
Other |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
Regulatory VaR |
|
|
|
|
|
|
|
|
Stressed VaR |
|
|
|
|
|
|
|
|
Incremental risk |
|
|
|
|
|
|
|
|
Comprehensive risk |
|
|
|
|
|
|
|
|
Specific risk |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
Derivatives |
|
|
$120,292 |
|
|
|
$111,691 |
|
Commitments, guarantees and loans |
|
|
176,501 |
|
|
|
151,587 |
|
Securities financing transactions |
|
|
71,427 |
|
|
|
16,568 |
|
Equity investments |
|
|
46,944 |
|
|
|
49,268 |
|
Other |
|
|
70,274 |
|
|
|
83,599 |
|
Total Credit RWAs |
|
|
485,438 |
|
|
|
412,713 |
|
|
|
|
|
|
|
|
|
|
Regulatory VaR |
|
|
14,913 |
|
|
|
14,913 |
|
Stressed VaR |
|
|
31,978 |
|
|
|
31,978 |
|
Incremental risk |
|
|
7,882 |
|
|
|
7,882 |
|
Comprehensive risk |
|
|
1,758 |
|
|
|
1,758 |
|
Specific risk |
|
|
12,193 |
|
|
|
12,193 |
|
Total Market RWAs |
|
|
68,724 |
|
|
|
68,724 |
|
|
|
|
– |
|
|
|
128,313 |
|
Total RWAs |
|
|
$554,162 |
|
|
|
$609,750 |
| In the table above:
| • |
|
Securities financing transactions represents resale and repurchase agreements and securities borrowed and loaned transactions. |
| • |
|
Other includes receivables, certain debt securities, cash and cash equivalents, and other assets. | The table below presents changes in RWAs.
|
|
|
|
|
|
|
|
|
| |
|
|
|
|
Standardized |
|
|
Advanced |
|
Nine Months Ended September 2021 |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
Beginning balance |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
Change in: |
|
|
|
|
|
|
|
|
Derivatives |
|
|
|
|
|
|
|
|
Commitments, guarantees and loans |
|
|
|
|
|
|
|
|
Securities financing transactions |
|
|
|
|
|
|
|
|
Equity investments |
|
|
|
|
|
|
|
|
Other |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
Change in: |
|
|
|
|
|
|
|
|
Regulatory VaR |
|
|
|
|
|
|
|
|
Stressed VaR |
|
|
|
|
|
|
|
|
Incremental risk |
|
|
|
|
|
|
|
|
Comprehensive risk |
|
|
|
|
|
|
|
|
Specific risk |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
Change in Operational RWAs |
|
|
– |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
Beginning balance |
|
|
$563,575 |
|
|
|
$544,653 |
|
|
|
|
|
|
|
|
|
|
Change in: |
|
|
|
|
|
|
|
|
Derivatives |
|
|
(614 |
) |
|
|
39,060 |
|
Commitments, guarantees and loans |
|
|
(3,239 |
) |
|
|
17,131 |
|
Securities financing transactions |
|
|
5,560 |
|
|
|
2,734 |
|
Equity investments |
|
|
(9,870 |
) |
|
|
(12,624 |
) |
Other |
|
|
(5,386 |
) |
|
|
5,333 |
|
Change in Credit RWAs |
|
|
(13,549 |
) |
|
|
51,634 |
|
|
|
|
|
|
|
|
|
|
Change in: |
|
|
|
|
|
|
|
|
Regulatory VaR |
|
|
5,980 |
|
|
|
5,980 |
|
Stressed VaR |
|
|
1,067 |
|
|
|
1,067 |
|
Incremental risk |
|
|
3,574 |
|
|
|
3,574 |
|
Comprehensive risk |
|
|
365 |
|
|
|
567 |
|
Specific risk |
|
|
(6,850 |
) |
|
|
(6,850 |
) |
Change in Market RWAs |
|
|
4,136 |
|
|
|
4,338 |
|
Change in Operational RWAs |
|
|
|
|
|
|
9,125 |
|
Ending balance |
|
|
$554,162 |
|
|
|
$609,750 |
| RWAs Rollforward Commentary Nine Months Ended September Standardized Credit RWAs as of September 2021 increased by $97.19 billion compared with December 2020, primarily reflecting an increase in commitments, guarantees and loans (principally due to increased lending activity and revisions to certain interpretations of the Capital Rules underlying the RWA calculations based on regulatory feedback), an increase in derivatives (principally due to increased exposures) and an increase in securities financing transactions (principally due to increased exposures and revisions to certain interpretations of the Capital Rules noted above). Standardized Market RWAs as of September 2021 increased by $12.58 billion compared with December 2020, primarily reflecting an increase in stressed VaR (principally due to increased exposures to interest rates) and an increase in specific risk (principally due to increased exposures to securitized products). Advanced Credit RWAs as of September 2021 increased by $46.98 billion compared with December 2020, primarily reflecting an increase in commitments, guarantees and loans (principally due to increased lending activity), an increase in other credit RWAs (principally due to increased receivables exposures) and an increase in equity investments (principally due to increased exposures as a result of gains, partially offset by sales). Advanced Market RWAs as of September 2021 increased by $12.58 billion compared with December 2020, primarily reflecting an increase in stressed VaR (principally due to increased exposures to interest rates) and an increase in specific risk (principally due to increased exposures to securitized products). Standardized Credit RWAs as of December 2020 decreased by $13.55 billion compared with December 2019, primarily reflecting a decrease in equity investments (principally due to the sale of certain equity positions) and a decrease in other (principally due to decreased receivables as a result of changes in risk measurements). These decreases were partially offset by an increase in securities financing transactions (principally due to increased funding exposures). Standardized Market RWAs as of December 2020 increased by $4.14 billion compared with December 2019, primarily reflecting an increase in regulatory VaR (principally due to increased market volatility) and an increase in incremental risk (principally due to increased exposures in equities held for market-making purposes). These increases were partially offset by a decrease in specific risk (principally due to changes in risk measurements on certain exposures). Advanced Credit RWAs as of December 2020 increased by $51.63 billion compared with December 2019, primarily reflecting an increase in derivatives (principally due to the impact of higher levels of volatility and counterparty credit risk) and an increase in commitments, guarantees and loans (principally due to increased lending activity). These increases were partially offset by a decrease in equity investments (principally due to the sale of certain equity positions). Advanced Market RWAs as of December 2020 increased by $4.34 billion compared with December 2019, primarily reflecting an increase in regulatory VaR (principally due to increased market volatility) and an increase in incremental risk (principally due to increased exposures in equities held for market-making purposes). These increases were partially offset by a decrease in specific risk (principally due to changes in risk measurements on certain exposures). Advanced Operational RWAs as of December 2020 increased by $9.13 billion compared with December 2019. The vast majority of this increase was associated with litigation and regulatory proceedings. Regulatory Capital Ratios. GS Bank USA, the firm’s primary U.S. bank subsidiary, is an FDIC-insured, New York State-chartered bank and a member of the Federal Reserve System, is supervised and regulated by the FRB, the FDIC, the New York State Department of Financial Services (NYDFS) and the Consumer Financial Protection Bureau, and is subject to regulatory capital requirements that are calculated under the Capital Framework. On July 1, 2021, GS Bank USA acquired GSBE, a non-U.S. banking subsidiary of the firm, which is also subject to standalone regulatory capital requirements noted below. GS Bank USA is an Advanced approach banking organization under the Capital Framework. The Capital Framework includes the minimum risk-based capital and the capital conservation buffer requirements (consisting of a 2.5% buffer and the countercyclical capital buffer). The buffer must consist entirely of capital that qualifies as CET1 capital. In addition, the Capital Framework includes the leverage ratio requirement. GS Bank USA is required to calculate the CET1 capital, Tier 1 capital and Total capital ratios in accordance with both the Standardized and Advanced Capital Rules. The lower of each risk-based capital ratio under the Standardized and Advanced Capital Rules is the ratio against which GS Bank USA’s compliance with its risk-based capital requirements is assessed. In addition, under the regulatory framework for prompt corrective action applicable to GS Bank USA, in order to meet the quantitative requirements for a “well-capitalized” depository institution, GS Bank USA must also meet the “well-capitalized” requirements in the table below. GS Bank USA’s capital levels and prompt corrective action classification are also subject to qualitative judgments by the regulators about components of capital, risk weightings and other factors. Failure to comply with the capital requirements, including a breach of the buffers described below, could result in restrictions being imposed by the regulators. The table below presents GS Bank USA’s risk-based capital, leverage and “well-capitalized” requirements.
|
|
|
|
|
|
|
|
|
| |
|
|
|
|
|
|
|
|
|
“Well-capitalized” Requirements |
|
Risk-based capital requirements |
|
|
|
|
|
CET1 capital ratio |
|
|
|
|
|
|
|
|
Tier 1 capital ratio |
|
|
|
|
|
|
|
|
Total capital ratio |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
Tier 1 leverage ratio |
|
|
|
|
|
|
|
|
SLR |
|
|
|
|
|
|
|
| In the table above:
| • |
|
The CET1 capital ratio requirement includes a minimum of 4.5%, the Tier 1 capital ratio requirement includes a minimum of 6.0% and the Total capital ratio requirement includes a minimum of 8.0%. These requirements also include the capital conservation buffer requirements consisting of a 2.5% buffer and the countercyclical capital buffer, which the FRB has set to zero percent. |
| • |
|
The “well-capitalized” requirements are the binding requirements for leverage ratios. | The table below presents information about GS Bank USA’s risk-based capital ratios.
|
|
|
|
|
|
|
|
|
| |
|
|
|
|
|
Standardized |
|
|
|
Advanced |
|
|
|
|
|
|
|
|
|
|
CET1 capital |
|
|
|
|
|
|
|
|
Tier 1 capital |
|
|
|
|
|
|
|
|
Tier 2 capital |
|
|
|
|
|
|
|
|
Total capital |
|
|
|
|
|
|
|
|
RWAs |
|
|
|
|
|
|
|
|
CET1 capital ratio |
|
|
|
|
|
|
|
|
Tier 1 capital ratio |
|
|
|
|
|
|
|
|
Total capital ratio |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
CET1 capital |
|
|
$ 34,687 |
|
|
|
$ 34,687 |
|
Tier 1 capital |
|
|
$ 34,687 |
|
|
|
$ 34,687 |
|
Tier 2 capital |
|
|
$ 6,312 |
|
|
|
$ 4,963 |
|
Total capital |
|
|
$ 40,999 |
|
|
|
$ 39,650 |
|
RWAs |
|
|
$280,877 |
|
|
|
$173,442 |
|
CET1 capital ratio |
|
|
12.3% |
|
|
|
20.0% |
|
Tier 1 capital ratio |
|
|
12.3% |
|
|
|
20.0% |
|
Total capital ratio |
|
|
14.6% |
|
|
|
22.9% |
| In the table above:
| • |
|
In accordance with the reporting requirements for business combinations of entities under common control, prior period amounts are presented as if the acquisition of GSBE by GS Bank USA had occurred at the beginning of 2020. |
| • |
|
The lower of the Standardized or Advanced ratio is the ratio against which GS Bank USA’s compliance with the capital requirements is assessed under the risk-based Capital Rules, and therefore, the Standardized ratios applied to GS Bank USA as of both September 2021 and December 2020. |
| • |
|
As permitted by the FRB, GS Bank USA elected to temporarily delay the estimated effects of adopting CECL on regulatory capital until January 2022 and to subsequently phase-in the effects through January 2025. In addition, GS Bank USA elected to increase regulatory capital by 25% of the increase in the allowance for credit losses since January 1, 2020, as permitted by the rules issued by the FRB. The impact of this increase will also be phased in over the three-year transition period. Reflecting the full impact of CECL as of both September 2021 and December 2020 would not have had a material impact on GS Bank USA’s Standardized risk-based capital ratios. |
| • |
|
The Standardized and Advanced risk-based capital ratios decreased from December 2020 to September 2021, reflecting an increase in both Credit and Market RWAs, partially offset by an increase in capital, principally due to net capital contributions and net earnings. |
| • |
|
In connection with the regulatory feedback the firm received in the third quarter of 2021, GS Bank USA revised certain interpretations of the Capital Rules underlying the calculation of Standardized RWAs, which increased GS Bank USA’s Standardized RWAs by approximately $10 billion and reduced GS Bank USA’s Standardized CET1, Standardized Tier 1 and Standardized Total capital ratios by 0.4 percentage points as of September 2021. As of December 2020, this change would have increased GS Bank USA’s Standardized RWAs of $281 billion by approximately $11 billion, which would have reduced GS Bank USA’s Standardized CET1 capital ratio of 12.3% by 0.4 percentage points, Standardized Tier 1 capital ratio of 12.3% by 0.4 percentage points and Standardized Total capital ratio of 14.6% by 0.6 percentage points. | The table below presents information about GS Bank USA’s leverage ratios.
|
|
|
|
|
|
|
|
|
| |
|
| |
|
For the Three Months Ended or as of |
|
| |
|
|
|
|
|
|
|
|
|
December 2020 |
|
Tier 1 capital |
|
|
|
|
|
|
$ 34,687 |
|
Average adjusted total assets |
|
|
|
|
|
|
$310,690 |
|
Total leverage exposure |
|
|
|
|
|
|
$381,637 |
|
|
|
|
|
|
|
|
11.2% |
|
|
|
|
|
|
|
|
9.1% |
| In the table above:
| • |
|
In accordance with the reporting requirements for business combinations of entities under common control, prior period amounts are presented as if the acquisition of GSBE by GS Bank USA had occurred at the beginning of 2020. |
| • |
|
Average adjusted total assets represents the average daily assets for the quarter adjusted for deductions from Tier 1 capital and the impact of CECL transition. |
| • |
|
Total leverage exposure, for the three months ended December 2020, excluded average holdings of U.S. Treasury securities and average deposits at the Federal Reserve as permitted by the FRB under a temporary amendment. The impact of this temporary amendment was an increase in GS Bank USA’s SLR by approximately 2.4 percentage points for the three months ended December 2020. The amendment permitting this exclusion expired on April 1, 2021. |
| • |
|
Tier 1 leverage ratio is calculated as Tier 1 capital divided by average adjusted total assets. |
• |
|
SLR is calculated as Tier 1 capital divided by total leverage exposure. | The firm’s principal non-U.S. bank subsidiaries, GSIB and GSBE, are also subject to regulatory capital requirements. GSIB is regulated by the Prudential Regulation Authority (PRA) and the Financial Conduct Authority (FCA), and GSBE is directly supervised by the European Central Bank and by BaFin and Deutsche Bundesbank in the context of the E.U. Single Supervisory Mechanism. As of both September 2021 and December 2020, GSIB and GSBE were in compliance with their regulatory capital requirements. The deposits of GS Bank USA are insured by the FDIC to the extent provided by law. The FRB requires that GS Bank USA maintain cash reserves with the Federal Reserve. As of both September 2021 and December 2020, the reserve requirement ratio was zero percent. The amount deposited by GS Bank USA at the Federal Reserve was $100.93 billion as of September 2021 and $52.71 billion as of December 2020. Group Inc. may be limited in its ability to access capital held at certain subsidiaries as a result of regulatory, tax or other constraints. These limitations include provisions of applicable law and regulations and other regulatory restrictions that limit the ability of those subsidiaries to declare and pay dividends without prior regulatory approval. For example, the amount of dividends that may be paid by GS Bank USA are limited to the lesser of the amounts calculated under a recent earnings test and an undivided profits test. As a result of dividends paid in connection with the acquisition of GSBE in July 2021, GS Bank USA cannot currently declare any additional dividends without prior regulatory approval. In addition, subsidiaries not subject to separate regulatory capital requirements may hold capital to satisfy local tax and legal guidelines, rating agency requirements (for entities with assigned credit ratings) or internal policies, including policies concerning the minimum amount of capital a subsidiary should hold based on its underlying level of risk. Group Inc.’s equity investment in subsidiaries was $114.93 billion as of September 2021 and $103.80 billion as of December 2020, of which Group Inc. was required to maintain $83.57 billion as of September 2021 and $63.68 billion as of December 2020, of minimum equity capital in its regulated subsidiaries in order to satisfy the regulatory requirements of such subsidiaries. Group Inc.’s capital invested in certain non-U.S. subsidiaries is exposed to foreign exchange risk, substantially all of which is managed through a combination of derivatives and non-U.S. denominated debt. See Note 7 for information about the firm’s net investment hedges used to hedge this risk.
|