v3.22.0.1
Regulation and Capital Adequacy
12 Months Ended
Dec. 31, 2021
Text Block [Abstract]  
Regulation and Capital Adequacy
Note 20.
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 would 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.
Capital Framework
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.
 
 
    Standardized        Advanced  
As of December 2021
                
CET1 capital ratio
 
 
13.4%
 
  
 
9.5%
 
Tier 1 capital ratio
 
 
14.9%
 
  
 
11.0%
 
Total capital ratio
 
 
16.9%
 
  
 
13.0%
 
 
As of December 2020
                
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:
 
 
As of both December 2021 and December 2020, 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 6.4% as of December 2021 and 6.6% as of December 2020 under the Standardized Capital Rules and a buffer of 2.5% as of both December 2021 and December 2020 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.
The table below presents information about risk-based capital ratios.
 
$ in millions
    Standardized        Advanced  
As of December 2021
                
CET1 capital
 
 
$  96,254
 
  
 
$  96,254
 
Tier 1 capital
 
 
$106,766
 
  
 
$106,766
 
Tier 2 capital
 
 
$  14,636
 
  
 
$  12,051
 
Total capital
 
 
$121,402
 
  
 
$118,817
 
RWAs
 
 
$676,863
 
  
 
$647,921
 
 
CET1 capital ratio
 
 
14.2%
 
  
 
14.9%
 
Tier 1 capital ratio
 
 
15.8%
 
  
 
16.5%
 
Total capital ratio
 
 
17.9%
 
  
 
18.3%
 
 
As of December 2020
                
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%  
In the table above,
 
 
As 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 December 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. 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 capital 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.
 
 
In December 2021, the firm early adopted the U.S. federal bank regulatory agencies’ final rule that implements the new standardized approach for counterparty credit risk
(SA-CCR).
SA-CCR
replaced the current exposure method for calculating the exposure amount of derivative contracts for determining Standardized RWAs and supplementary leverage exposure. Adoption of
SA-CCR
resulted in a decrease to the firm’s Standardized CET1 capital ratio by approximately 0.3 percentage points as of December 2021.
Leverage Ratios.
The table below presents the leverage requirements.
 
 
 
 
Requirements
 
Tier 1 leverage ratio
 
 
4.0%
 
SLR
 
 
5.0%
 
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
 
     
$ in millions
 
 
2021
 
     2020  
Tier 1 capital
 
 
$  
 
106,766
 
     $     92,730  
 
Average total assets
 
 
$1,466,770
 
     $1,152,785  
Deductions from Tier 1 capital
 
 
(4,583
     (4,948
Average adjusted total assets
 
 
1,462,187
 
     1,147,837  
Impact of SLR temporary amendment
 
 
 
     (202,748
Off-balance
sheet and other exposures
 
 
448,334
 
     387,848  
Total leverage exposure
 
 
$1,910,521
 
     $1,332,937  
 
Tier 1 leverage ratio
 
 
7.3%
 
     8.1%  
SLR
 
 
5.6%
 
     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.
 
 
Off-balance sheet and other exposures primarily includes the monthly average of
off-balance
sheet exposures, consisting 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. Adoption of
SA-CCR
in December 2021, as described above, did not result in a material impact to the firm’s SLR for the three months ended December 2021.
Risk-Based Capital.
The table below presents information about risk-based capital.

    As of December  
     
$ in millions
 
 
2021
 
     2020  
Common shareholders’ equity
 
 
$  99,223
 
     $  84,729  
Impact of CECL transition
 
 
1,105
 
     1,126  
Deduction for goodwill
 
 
(3,610
     (3,652
Deduction for identifiable intangible assets
 
 
(401
     (601
Other adjustments
 
 
(63
     39  
CET1 capital
 
 
96,254
 
     81,641  
Preferred stock
 
 
10,703
 
     11,203  
Deduction for investments in covered funds
 
 
(189
     (106
Other adjustments
 
 
(2
     (8
Tier 1 capital
 
 
$106,766
 
     $  92,730  
 
Standardized Tier 2 and Total capital
                
Tier 1 capital
 
 
$106,766
 
     $  92,730  
Qualifying subordinated debt
 
 
11,554
 
     12,196  
Junior subordinated debt
 
 
94
 
     188  
Allowance for credit losses
 
 
3,034
 
     3,095  
Other adjustments
 
 
(46
     (55
Standardized Tier 2 capital
 
 
14,636
 
     15,424  
Standardized Total capital
 
 
$121,402
 
     $108,154  
 
Advanced Tier 2 and Total capital
                
Tier 1 capital
 
 
$106,766
 
     $  92,730  
Standardized Tier 2 capital
 
 
14,636
 
     15,424  
Allowance for credit losses
 
 
(3,034
     (3,095
Other adjustments
 
 
449
 
     950  
Advanced Tier 2 capital
 
 
12,051
 
     13,279  
Advanced Total capital
 
 
$118,817
 
     $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 $675 million as of December 2021 and $680 million as of December 2020.
 
 
Deduction for identifiable intangible assets was net of deferred tax liabilities of $17 million as of December 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 December 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 was fully phased out of Tier 2 capital beginning in January 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.
 
$ in millions
    Standardized       Advanced  
Year Ended December 2021
               
CET1 capital
               
Beginning balance
 
 
$  81,641
 
 
 
$  81,641
 
Change in:
               
Common shareholders’ equity
 
 
14,494
 
 
 
14,494
 
Impact of CECL transition
 
 
(21
 
 
(21
Deduction for goodwill
 
 
42
 
 
 
42
 
Deduction for identifiable intangible assets
 
 
200
 
 
 
200
 
Other adjustments
 
 
(102
 
 
(102
Ending balance
 
 
$  96,254
 
 
 
$  96,254
 
 
Tier 1 capital
               
Beginning balance
 
 
$  92,730
 
 
 
$  92,730
 
Change in:
               
CET1 capital
 
 
14,613
 
 
 
14,613
 
Deduction for investments in covered funds
 
 
(83
 
 
(83
Preferred stock
 
 
(500
 
 
(500
Other adjustments
 
 
6
 
 
 
6
 
Ending balance
 
 
106,766
 
 
 
106,766
 
Tier 2 capital
               
Beginning balance
 
 
15,424
 
 
 
13,279
 
Change in:
               
Qualifying subordinated debt
 
 
(642
 
 
(642
Junior subordinated debt
 
 
(94
 
 
(94
Allowance for credit losses
 
 
(61
 
 
 
Other adjustments
 
 
9
 
 
 
(492
Ending balance
 
 
14,636
 
 
 
12,051
 
Total capital
 
 
$121,402
 
 
 
$118,817
 
 
Year Ended December 2020
               
CET1 capital
               
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  
 
Tier 1 capital
               
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  
Tier 2 capital
               
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.
RWAs are calculated in accordance with both the Standardized and Advanced Capital Rules.
Credit Risk
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.
Market Risk
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:
 
 
Value-at-Risk
(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 exceeded its 99%
one-day
regulatory VaR on one occasion during 2021 and 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 Risk
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.
 
$ in millions
    Standardized        Advanced  
As of December 2021
                
Credit RWAs
                
Derivatives
 
 
$175,628
 
  
 
$109,532
 
Commitments, guarantees and loans
 
 
233,639
 
  
 
182,210
 
Securities financing transactions
 
 
 
76,346
 
  
 
14,407
 
Equity investments
 
 
43,256
 
  
 
45,582
 
Other
 
 
71,485
 
  
 
86,768
 
Total Credit RWAs
 
 
600,354
 
  
 
438,499
 
Market RWAs
                
Regulatory VaR
 
 
13,510
 
  
 
13,510
 
Stressed VaR
 
 
38,922
 
  
 
38,922
 
Incremental risk
 
 
6,867
 
  
 
6,867
 
Comprehensive risk
 
 
2,521
 
  
 
2,521
 
Specific risk
 
 
14,689
 
  
 
14,689
 
Total Market RWAs
 
 
76,509
 
  
 
76,509
 
Total Operational RWAs
 
 
 
  
 
132,913
 
Total RWAs
 
 
$676,863
 
  
 
$647,921
 
 
As of December 2020
                
Credit RWAs
                
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  
Market RWAs
                
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  
Total Operational RWAs
           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.
 
$ in millions
    Standardized        Advanced  
Year Ended December 2021
                
RWAs
                
Beginning balance
 
 
$554,162
 
  
 
$609,750
 
Credit RWAs
                
Change in:
                
Derivatives
 
 
55,336
 
  
 
(2,159
Commitments, guarantees and loans
 
 
57,138
 
  
 
30,623
 
Securities financing transactions
 
 
4,919
 
  
 
(2,161
Equity investments
 
 
(3,688
  
 
(3,686
Other
 
 
1,211
 
  
 
3,169
 
Change in Credit RWAs
 
 
114,916
 
  
 
25,786
 
Market RWAs
                
Change in:
                
Regulatory VaR
 
 
(1,403
  
 
(1,403
Stressed VaR
 
 
6,944
 
  
 
6,944
 
Incremental risk
 
 
(1,015
  
 
(1,015
Comprehensive risk
 
 
763
 
  
 
763
 
Specific risk
 
 
2,496
 
  
 
2,496
 
Change in Market RWAs
 
 
7,785
 
  
 
7,785
 
Change in Operational RWAs
 
 
 
  
 
4,600
 
Ending balance
 
 
$676,863
 
  
 
$647,921
 
 
Year Ended December 2020
                
RWAs
                
Beginning balance
    $563,575        $544,653  
Credit RWAs
                
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  
Market RWAs
                
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
Year Ended December 2021.
Standardized Credit RWAs as of December 2021 increased by $114.92 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 calculation based on regulatory feedback) and an increase in derivatives (principally due to increased exposures and the impact of SA-CCR adoption). Standardized Market RWAs as of December 2021 increased by $7.79 billion compared with December 2020, primarily reflecting an increase in stressed VaR (principally due to increased exposures to interest rates).
Advanced Credit RWAs as of December 2021 increased by $25.79 billion compared with December 2020, primarily reflecting an increase in commitments, guarantees and loans (principally due to increased lending activity). This increase was partially offset by a decrease in equity investments (principally due to the sale of equity positions). Advanced Market RWAs as of December 2021 increased by $7.79 billion compared with December 2020, primarily reflecting an increase in stressed VaR (principally due to increased exposures to interest rates). Advanced Operational RWAs as of December 2021 increased by $4.60 billion compared with December 2020, primarily associated with litigation and regulatory proceedings.
Year Ended December 2020.
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.
 
Bank Subsidiaries
GS Bank USA.
GS Bank USA is the firm’s primary U.S. bank subsidiary. GS Bank USA 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, would result in restrictions being imposed by the regulators.
The table below presents GS Bank USA’s risk-based capital, leverage and “well-capitalized” requirements.
 
 
 
 
Requirements
 
  
 
“Well-capitalized”

Requirements
 
 
Risk-based capital requirements
 
        
CET1 capital ratio
 
 
7.0%
 
  
 
6.5%
 
Tier 1 capital ratio
 
 
8.5%
 
  
 
8.0%
 
Total capital ratio
 
 
10.5%
 
  
 
10.0%
 
 
Leverage requirements
 
        
Tier 1 leverage ratio
 
 
4.0%
 
  
 
5.0%
 
SLR
 
 
3.0%
 
  
 
6.0%
 
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.
 
$ in millions
    Standardized        Advanced  
As of December 2021
                
CET1 capital
 
 
$  42,535
 
  
 
$  42,535
 
Tier 1 capital
 
 
$  42,535
 
  
 
$  42,535
 
Tier 2 capital
 
 
$    6,430
 
  
 
$    4,646
 
Total capital
 
 
$  48,965
 
  
 
$  47,181
 
RWAs
 
 
$312,601
 
  
 
$222,607
 
 
CET1 capital ratio
 
 
13.6%
 
  
 
19.1%
 
Tier 1 capital ratio
 
 
13.6%
 
  
 
19.1%
 
Total capital ratio
 
 
15.7%
 
  
 
21.2%
 
 
As of December 2020
                
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 December 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 December 2021 and December 2020 would not have had a material impact on GS Bank USA’s Standardized risk-based capital ratios.
 
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. 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.
 
 
In December 2021, GS Bank USA adopted
SA-CCR
,
which resulted in an increase to GS Bank USA’s Standardized CET1 capital ratio by approximately 1.9 percentage points as of December 2021.
 
 
The Standardized risk-based capital ratios increased from December 2020 to December 2021, reflecting an increase in capital due to capital contributions and net earnings, partially offset by an increase in both Credit and Market RWAs. The increase in Standardized Credit RWAs reflected 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 calculation based on regulatory feedback described above), partially offset by a decrease in derivatives (principally due to the impact of SA-CCR adoption described above). The increase in Standardized Market RWAs primarily reflected an increase in stressed VaR and regulatory VaR (in each case, principally due to increased exposures to interest rates).
 
 
The Advanced risk-based capital ratios decreased from December 2020 to December 2021, reflecting an increase in both Credit and Market RWAs, partially offset by an increase in capital due to capital contributions and net earnings. The increase in Advanced Credit RWAs reflected an increase in commitments, guarantees and loans (principally due to increased lending activity) and the increase in Advanced Market RWAs primarily reflected an increase in stressed VaR and regulatory VaR (in each case, principally due to increased exposures to interest rates).
The table below presents information about GS Bank USA’s leverage ratios.
 
    For the Three Months
Ended or as of December
 
     
$ in millions
 
 
2021
 
       2020  
Tier 1 capital
 
 
$  42,535
 
       $  34,687  
Average adjusted total assets
 
 
$409,739
 
       $310,690  
Total leverage exposure
 
 
$627,799
 
       $381,637  
 
Tier 1 leverage ratio
 
 
10.4%
 
       11.2%  
SLR
 
 
6.8%
 
       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. Adoption of
SA-CCR
in December 2021 resulted in an increase to GS Bank USA’s SLR by approximately 0.2 percentage points for the three months ended December 2021.
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 December 2021 and December 2020, the reserve requirement ratio was zero percent. The amount deposited by GS Bank USA at the Federal Reserve was $122.01 billion as of December 2021 and $52.71 billion as of December 2020.
GS Bank USA is a registered swap dealer with the CFTC and, beginning in the fourth quarter of 2021, also became a registered security-based swap dealer with the SEC. As of December 2021, GS Bank USA was subject to and in compliance with applicable capital requirements for swap dealers and security-based swap dealers.
GSIB.
GSIB is our U.K. bank subsidiary regulated by the Prudential Regulation Authority (PRA) and the Financial Conduct Authority (FCA). GSIB is subject to the U.K. capital framework, which is largely based on Basel III.
The table below presents GSIB’s risk-based capital requirements.
 
    As of December  
     
 
 
 
2021
 
     2020  
Risk-based capital requirements
                
CET1 capital ratio
 
 
8.5%
 
     8.3%  
Tier 1 capital ratio
 
 
10.5%
 
     10.3%  
Total capital ratio
 
 
13.2%
 
     12.9%  
The table below presents information about GSIB’s risk-based capital ratios.
 
    As of December  
     
$ in millions
 
 
2021
 
     2020  
Risk-based capital and risk-weighted assets
                
CET1 capital
 
 
$  3,408
 
     $  3,051  
Tier 1 capital
 
 
$  3,408
 
     $  3,051  
Tier 2 capital
 
 
$    
    
826
 
     $    
    
827
 
Total capital
 
 
$  4,234
 
     $  3,878  
RWAs
 
 
$17,196
 
     $19,263  
 
Risk-based capital ratios
                
CET1 capital ratio
 
 
19.8%
 
     15.8%  
Tier 1 capital ratio
 
 
19.8%
 
     15.8%  
Total capital ratio
 
 
24.6%
 
     20.1%  
In the table above, the risk-based capital ratios as of December 2021 reflected GSIB’s profits after foreseeable charges for the year ended December 2021 (which will not be finalized until verification by GSIB’s external auditors and approval by GSIB’s Board of Directors for inclusion in risk-based capital). These profits contributed approximately 68 basis points to the CET1 capital ratio.
The eligible retail deposits of GSIB are covered by the U.K. Financial Services Compensation Scheme to the extent provided by law.
GSIB is subject to minimum reserve requirements at the Bank of England. The minimum reserve requirement was $172 million as of December 2021 and $126 million as of December 2020. The amount deposited by GSIB at the Bank of England was $2.20 billion as of December 2021 and $9.82 billion as of December 2020.
GSBE.
GSBE is our German bank subsidiary supervised by the European Central Bank, BaFin and Deutsche Bundesbank. GSBE is subject to the capital requirements prescribed in the amended E.U. Capital Requirements Directive (CRD) and E.U. Capital Requirements Regulation (CRR), which are largely based on Basel III.
The table below presents GSBE’s risk-based capital requirements.
 
    As of December  
     
 
 
 
2021
 
     2020  
Risk-based capital requirements
                
CET1 capital ratio
 
 
8.7%
 
     7.0%  
Tier 1 capital ratio
 
 
10.8%
 
     8.5%  
Total capital ratio
 
 
13.5%
 
     10.5%  
The table below presents information about GSBE’s risk-based capital ratios.
 
    As of December  
     
$ in millions
 
 
2021
 
     2020  
Risk-based capital and risk-weighted assets
                
CET1 capital
 
 
$  6,527
 
     $  3,991  
Tier 1 capital
 
 
$  6,527
 
     $  3,991  
Tier 2 capital
 
 
$  
    
    23
 
     $       24  
Total capital
 
 
$  6,550
 
     $  4,015  
RWAs
 
 
$28,924
 
     $11,634  
 
Risk-based capital ratios
                
CET1 capital ratio
 
 
22.6%
 
     34.3%  
Tier 1 capital ratio
 
 
22.6%
 
     34.3%  
Total capital ratio
 
 
22.6%
 
     34.5%  
In the table above:
 
 
The risk-based capital ratios as of December 2021 reflected GSBE’s profits after foreseeable charges for the year ended December 2021 (which will not be finalized until verification by GSBE’s external auditors and approval by GSBE’s shareholder (GS Bank USA) for inclusion in risk-based capital). These profits contributed
approximately 106 basis points to the CET1 capital ratio.
 
 
Risk-based capital ratios as of December 2021 reflected the CRR and the CRD rules which implement changes in the Basel standards with respect to counterparty credit risk and large exposure. These rules became effective in June 2021. Adoption of these rules did not result in a material impact to GSBE’s risk-based capital ratios as of December 2021.
The table below presents GSBE’s leverage ratio requirement which became effective in June 2021 and the leverage ratio.
 
 
 
 
As of December 2021
 
Leverage ratio requirement
 
 
3.0%
 
Leverage ratio
 
 
7.6%
 
In the table above, the leverage ratio as of December 2021 reflected GSBE’s profits after foreseeable charges for the year ended December 2021 (which will not be finalized until verification by GSBE’s external auditors and approval by GSBE’s shareholder (GS Bank USA) for inclusion in risk-based capital). These profits contributed
approximately 58 basis points to the leverage ratio.
The deposits of GSBE are covered by the German statutory deposit protection program to the extent provided by law. In addition, GSBE has elected to participate in the German voluntary deposit protection program which provides insurance for certain eligible deposits not covered by the German statutory deposit program. GSBE is subject to minimum reserve requirements at central banks in certain of the jurisdictions in which it operates. The minimum reserve requirement was $189 million as of December 2021 and $25 million as of December 2020. The amount deposited by GSBE at central banks was $20.36 billion as of December 2021 and $3.17 billion as of December 2020, substantially all of which was deposited with Deutsche Bundesbank.
GSBE is a registered swap dealer with the CFTC and, beginning in the fourth quarter of 2021, also became a registered security-based swap dealer with the SEC. As of December 2021, GSBE was subject to and in compliance with applicable capital requirements for swap dealers and security-based swap dealers.
Restrictions on Payments
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 $118.90 billion as of December 2021 and $103.80 billion as of December 2020, of which Group Inc. was required to maintain $77.22 billion as of December 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.
dollar functional currency subsidiaries is exposed to foreign exchange risk, substantially all of which is managed through a combination of derivatives and
non-U.S.
dollar-denominated
debt. See Note 7 for information about the firm’s net investment hedges used to hedge this risk.