International Swaps and Derivatives Association, SIFMA and FIA urge US banking agencies to finalize enhanced supplementary leverage ratio recalibration by 1 January 2026

The International Swaps and Derivatives Association (ISDA), the Securities Industry and Financial Markets Association (SIFMA) and FIA submitted a joint comment letter to the Federal Reserve, Federal Deposit Insurance Corporation and Office of the Comptroller of the Currency supporting the proposed recalibration of the enhanced supplementary leverage ratio (eSLR) and related total loss-absorbing capacity (TLAC) and long-term debt (LTD) requirements. The associations argue the changes would restore the eSLR to its intended role as a backstop to risk-based capital requirements and reduce constraints on banks’ capacity to intermediate in US Treasury markets, particularly ahead of mandatory clearing for US Treasuries. The letter highlights that recalibration would reduce the likelihood of the eSLR becoming a binding constraint and support low-risk, high-volume activities such as US Treasury intermediation, with properly calibrated leverage rules framed as important for liquidity and resilience as mandatory clearing expands. It also calls for a broader review of the US regulatory capital framework, including recognition of cross-product netting under the standardized approach, consideration of reforms to Tier 1 leverage ratio requirements, and elimination of what it characterizes as redundant LTD requirements for US global systemically important banks. ISDA, SIFMA and FIA urged the agencies to finalize and implement the rule no later than 1 January 2026.