About | HeinOnline Law Journal Library | HeinOnline Law Journal Library | HeinOnline



1 [1] (August 5, 2025)

handle is hein.crs/sgihsgr0001 and id is 1 raw text is: 





Congressional Research Service
Inforrning the legislative debate since 1914


6mnmemsmom


                                                                                                  August 5, 2025

Bank Capital Requirements and Treasury Market Resiliency


Banks play an important role in Treasury markets, where
investors trade federal debt. Congress has focused on
Treasury market resilience, which is necessary to finance
federal borrowing and maintain broader financial stability.
The enhanced supplementary leverage ratio (eSLR) is a
capital requirement that applies to the eight globally
systemically important banks (G-SIBs). In June 2025, the
federal bank regulators proposed a rule to reduce the eSLR
to make it a backstop to risk-based capital requirements
that does not discourage [the G-SIBs] from engaging in
low-risk activities, such as Treasury market making.
Improved market making  could make Treasury markets less
fragile. But lower capital requirements could make the G-
SIBs more likely to fail and cause financial instability.

Background

Treasury  Market   Fragility
Treasury markets are typically highly liquid-trading is
relatively robust and at low cost. However, Treasury cash
or lending markets have recently had short-lasting bouts of
instability in 2014, 2019, 2020, and 2025, where liquidity
suddenly dried up. In each case, calm was quickly restored,
sometimes through injections of liquidity by the Federal
Reserve (Fed). None of these episodes had broader, lasting
negative effects on the financial system.

Historically, Treasury markets were less regulated than
other securities markets. In addition to the June eSLR
proposal, policymakers have initiated a series of reforms to
make  Treasury markets more resilient. Some of these
reforms have been largely implemented, such as greater
transparency, debt buybacks, and new standing Fed
facilities. Some have been finalized but are not yet in effect,
such as more central clearing. Some have been abandoned,
such as registration requirements for market participants.

Role of Banks  in Treasury  Markets
Most banks hold Treasuries as investments. Large banks are
required to hold a minimum amount of liquid assets, such
as Treasuries. Banks holding Treasuries as long-term
investments does not affect Treasury market resilience.

In addition, most primary dealers, who are the largest
broker-dealers in Treasury markets, are owned by either
large domestic or foreign banks. Broker-dealers (also called
Treasury dealers in the context of Treasury markets) are
market makers in bond markets: They hold an inventory of
securities to fulfill client orders to buy, sell, borrow, and
lend. For the market to be liquid, broker-dealers must be
willing to increase their inventories when more clients want
to sell and decrease their inventories when clients want to
buy. Broker-dealers are not the only major institutional


participants in the Treasury market, but they are the only
ones that routinely act as market makers.

What   Is the eSLR?
Capital adequacy is one of the primary safeguards against
bank insolvency. Safety and soundness regulation requires
banks to maintain various capital-to-asset ratios or face
remedial actions. One of these capital requirements is the
leverage ratio. Unlike risk-weighted capital ratios, in the
leverage ratio all assets are counted at full value.

The G-SIBs  must meet an eSLR of 5% company-wide  and
6%  for their bank subsidiaries to avoid restrictions on
dividends, buybacks, and bonuses. The eSLR includes
assets and (unlike the leverage ratio) off-balance-sheet
exposures in the denominator. It is the ratio of Tier 1 capital
in the numerator and unweighted exposures in the
denominator. Tier 1 capital is high-quality, loss-absorbing
forms of capital, such as common equity. For more
information, see CRS Report R47447, Bank Capital
Requirements: A Primer and Policy Issues.

What   Are the  G-SlBs?
The G-SIBs  are the eight banks (see Table 1) that
regulators believe pose the greatest risk to financial stability
if they were to fail. They are subject to the most stringent
safety and soundness regulations, including the eSLR and
an additional G-SIB surcharge, which is added to their risk-
weighted capital requirements based on each's systemic
importance. For more information, see CRS Report
R47876, Enhanced  Prudential Regulation of Large Banks.

How   Does  the eSLR  Affect Treasury  Markets?
Banks must simultaneously comply with multiple capital
requirements, some risk-weighted and some unweighted. At
a given point in time, whichever one requires the most
capital is the binding requirement for any given bank.
Leverage ratios, such as the eSLR, require banks to hold the
same amount  of capital against relatively low-risk assets
(such as Treasury securities) as they are required to hold
against high-risk assets. But leverage ratios discourage
banks from holding Treasuries only if they are the binding
(or close to binding) requirement. If risk-weighted
requirements are binding, then banks face little disincentive
to hold Treasuries, because their risk weight is zero.

What   Is T LAC?
G-SIBs are also required to hold minimum total loss
absorbing capacity (TLAC) at the holding company level
that is composed of Tier 1 capital and long-term debt.
TLAC   is intended to bail in creditors and recapitalize a
failed G-SIB. There are currently weighted and unweighted
TLAC  requirements-the  latter is tied to the eSLR.


igross.gov