Prudential Regulator Hearing Highlights Bank Capital Reform

December 9, 2025

On December 2, the House Financial Services Committee (HFSC) held a hearing titled, “Oversight of Prudential Regulators.” 

Committee members stressed the need to tailor prudential standards, index regulatory thresholds to inflation, and reevaluate capital and leverage requirements. Witnesses confirmed they are reviewing the entire capital framework and exploring efforts that promote indexing and simplification.

Witnesses included the following top financial regulators:

  • Michelle Bowman – Vice Chair for Supervision, Board of Governors of the Federal Reserve System
  • Jonathan Gould – Comptroller, Office of the Comptroller of the Currency (OCC)
  • Kyle Hauptman – Chairman, National Credit Union Association (NCUA)
  • Travis Hill – Acting Chairman, Federal Deposit Insurance Corporation (FDIC)

Bank capital requirements featured prominently during the hearing, with Vice Chair Bowman continuing to voice support for tailoring bank regulations based on institutional size, complexity, and risk. 

  • In response to HFSC Chair French Hill’s query on whether Congress should statutorily mandate periodic reviews of bank asset-based regulatory thresholds, Bowman agreed that indexing is a critical component of the regulatory framework.
  • Bowman also shared that the Fed is conducting a comprehensive review of its entire regulatory framework to determine if the established categories remain fit for purpose.

Basel III proposal

  • HFSC members asked Bowman if the prior Basel proposal’s changes to the p-factor were excessive. The p-factor is a key component in measuring capital requirements for securitizations and the proposed changes were one of CREFC’s main concerns with the previous proposal.
  • Bowman explained that the regulatory agencies are developing the new Basel proposal from a risk-focused, bottom-up perspective:
My approach is to address the calibration of the new framework from the bottom up, rather than reverse engineer changes to achieve pre-determined or preconceived approaches to capital requirements.
  • She also affirmed that the banking agencies’ goal is to create a rule consistent with the 2017 Basel agreement, ensuring it does not go beyond the scope of the agreement unless it is to the benefit of U.S. institutions. She also noted that a capital neutral outcome is not necessarily the goal of the regulators.

What's next: CREFC is closely monitoring regulatory developments and looks forward to commenting on the forthcoming Basel III proposal.

Please contact Sairah Burki (sburki@crefc.org) with questions.

Contact  

Sairah Burki
Managing Director,
Head of Regulatory Affairs
703.201.4294
sburki@crefc.org
The information provided herein is general in nature and for educational purposes only. CRE Finance Council makes no representations as to the accuracy, completeness, timeliness, validity, usefulness, or suitability of the information provided. The information should not be relied upon or interpreted as legal, financial, tax, accounting, investment, commercial or other advice, and CRE Finance Council disclaims all liability for any such reliance. © 2025 CRE Finance Council. All rights reserved.

Become a Member

CREFC offers industry participants an unparalleled ability to connect, participate, advocate and learn!
Join Now

Sign Up for eNews

Subscribe