Leaders Insights
Leaders Insights

Rester au meilleur niveau, un peu chaque jour.

DomainesMarketingDataFinanceIA
RessourcesApprendreTestOutilsBlogGlossaire
© 2026 Leaders Insights — Tous droits réservés.
Formations/Banking: how the sector works/Regulation, major laws and compliance/Basel and the capital rulebook in practice
2/5+150 XP

Regulation, major laws and compliance

10The regulators who can shut your bank down+15011Basel and the capital rulebook in practice+15012KYC, AML and the cost of dirty money+15013Protecting the customer: conduct and fair treatment+15014Building a compliance function that survives an audit+150

Basel and the capital rulebook in practice

# Basel and the capital rulebook in practice

Every quarter, a bank like JPMorgan Chase or Deutsche Bank files a number that determines whether it can pay dividends, hand out bonuses, or buy back shares. That number is its CET1 ratio, and if it drops below a regulator-set threshold, the automatic consequence is not a fine. It is a freeze on payouts. This lesson traces how the Basel framework becomes that single reported figure, and what happens when the figure comes up short.

Where the rules come from

The Basel Committee on Banking Supervision (BCBS) is a standard-setting body hosted by the Bank for International Settlements in Basel, Switzerland. It has no legal power. It writes standards; individual jurisdictions then turn them into binding law.

  • In the United States, Basel is implemented by the Federal Reserve, the Office of the Comptroller of the Currency (OCC), and the FDIC.
  • In the European Union, it becomes law through the Capital Requirements Regulation (CRR) and Capital Requirements Directive (CRD), supervised by the European Central Bank (ECB) for large banks and the European Banking Authority (EBA) for rulemaking.
  • In the UK, the Prudential Regulation Authority (PRA) does the job.

The current package, often called Basel III (and its final pieces, sometimes labeled "Basel III endgame" in the US or "Basel 3.1" in the UK), was designed after the 2008 crisis to make sure banks hold enough loss-absorbing capital and enough cash-like assets to survive a run.

The full standards are public. You can read them on the
BIS Basel Framework site
.

The three numbers that matter

Basel III boils down, in practice, to three headline constraints a bank reports and must never breach.

1. The CET1 capital ratio

CET1 stands for Common Equity Tier 1. It is the highest-quality capital: mostly common shares and retained earnings, the money that absorbs losses first.

The ratio is:

CET1 ratio = CET1 capital / Risk-Weighted Assets (RWA)

Risk-Weighted Assets (RWA) is the key twist. You do not divide by total assets. You weight each asset by how risky it is. A government bond might carry a 0% risk weight (counts for nothing), a mortgage maybe 35%, an unsecured corporate loan 100% or more.

The Basel minimum for CET1 is 4.5% of RWA. But nobody runs at 4.5%. On top sit several buffers:

  • Capital conservation buffer: +2.5%
  • Countercyclical buffer: 0% to 2.5%, set by national regulators depending on the credit cycle
  • G-SIB surcharge: an extra charge for a Global Systemically Important Bank (the biggest, most interconnected banks), typically +1% to +3.5%

Stack these and a large bank's effective CET1 requirement often lands around 9% to 13%, depending on the institution and jurisdiction (estimate, varies by bank and year).

A worked example

Say a mid-size bank has:

  • CET1 capital: 12 billion USD
  • RWA: 120 billion USD
CET1 ratio = 12 / 120 = 10.0%

Suppose this bank's required minimum plus buffers is 9.5%. It has a 0.5% cushion. That is 600 million USD of headroom (0.5% of 120 billion). If loan losses wipe out 700 million of capital, the ratio falls to roughly 9.4%, below the buffer, and restrictions kick in.

2. the liquidity coverage ratio (LCR)

Capital is about solvency. Liquidity is about surviving a bank run. The Liquidity Coverage Ratio (LCR) asks: if depositors and counterparties pulled funds for 30 days of stress, do you hold enough high-quality liquid assets (HQLA) to cover it?

LCR = High-Quality Liquid Assets / Net cash outflows over 30 days

The minimum is 100%. You must hold at least one dollar of liquid assets (cash, central bank reserves, top-rated government bonds) for every dollar you might have to pay out in a 30-day crisis.

This rule was written with 2008 in mind, when banks like Lehman Brothers had assets but no cash when the market froze. The 2023 failure of Silicon Valley Bank was, in part, a liquidity event: deposits fled faster than assets could be sold.

3. the leverage ratio

The CET1 ratio can be gamed by loading up on low-risk-weighted assets. The leverage ratio is the backstop that ignores risk weights entirely:

Leverage ratio = Tier 1 capital / Total exposure (unweighted)

The Basel minimum is 3%. G-SIBs face a higher requirement (in the US, large banks are subject to an enhanced Supplementary Leverage Ratio). The point: no matter how "safe" your assets look on paper, you cannot borrow more than roughly 33 times your capital.

What happens if you breach

Here is the teeth of the framework. Breaching the buffer does not immediately shut the bank down. Instead it triggers the Maximum Distributable Amount (MDA).

The MDA is a cap on what the bank can pay out: dividends, share buybacks, and discretionary bonus payments to staff. The deeper you dip into the buffer, the tighter the cap.

Roughly (under EU CRD rules):

  • Enter the top quarter of the buffer shortfall: you may distribute up to 60% of eligible profits
  • Deeper: 40%, then 20%
  • Bottom quarter: 0%. No dividend, no buyback, no bonus pool.

So the "specific number" your bank reports every quarter is not academic. Miss the buffer and the compensation committee's bonus plan and the board's dividend both freeze automatically. This is why bank CFOs manage CET1 to a target well above the minimum, holding what they call a "management buffer" on top of the regulatory one.

How the number actually gets reported

Large US banks file the FR Y-9C and related regulatory reports with the Federal Reserve. In the EU, banks submit COREP (Common Reporting) for capital and FINREP for financial data to their supervisor via the EBA's harmonized templates.

These are quarterly. Each filing states the CET1 ratio, LCR, and leverage ratio to the decimal. Supervisors compare them against thresholds and against the bank's own stress-test results.

Stress testing is the other half. In the US, the Fed runs the annual CCAR / DFAST (Comprehensive Capital Analysis and Review / Dodd-Frank Act Stress Test) exercise. It models a severe recession and asks: does your CET1 ratio stay above the minimum through the downturn? The result sets your Stress Capital Buffer, which feeds directly back into the CET1 requirement you must hold. So the stress test and the quarterly number are linked in a loop.

Vérification des acquis

1. When a bank's CET1 ratio falls below the regulator-set threshold, what is the described automatic consequence?

2. What best explains why the Basel Committee itself cannot force a bank to hold more capital?

3. Why is CET1 considered the highest-quality form of regulatory capital?

CHOIX MULTIPLES

4. Select ALL correct answers about how the Basel framework is implemented across jurisdictions.

Sélectionnez toutes les réponses correctes.

CHOIX MULTIPLES

5. Select ALL correct answers describing the design goals of the post-2008 Basel III package.

Sélectionnez toutes les réponses correctes.

Practical constraints this imposes

The rulebook shapes daily banking decisions, not just quarterly filings.

Lending choices. Because RWA drives the denominator, a loan's risk weight affects how much capital it consumes. A bank short on CET1 may favor low-risk-weight lending (mortgages, government exposures) over higher-weight corporate or unsecured loans, tightening credit exactly where risk weights are high.

Business mix. Trading books, securitizations, and complex derivatives attract heavy capital charges under the finalized Basel rules. Several banks have trimmed these activities partly to save capital.

The "endgame" fight. In the US, the proposed Basel III endgame rules would raise RWA for large banks. As of early 2026, the exact calibration has been contested and revised after heavy bank lobbying, with regulators signaling a lighter version than the 2023 draft. Treat any specific percentage increase you hear as an estimate until the final rule is confirmed.

Divergence across regions. The EU and UK have set their own timelines and carve-outs (for example, treatment of certain mortgage and SME exposures differs). A global bank must satisfy the strictest applicable regulator in each jurisdiction, not a single global standard.

Key Takeaways

  • The CET1 ratio (CET1 capital / risk-weighted assets) is the single most important number a bank reports quarterly. The Basel minimum is 4.5%, but buffers push effective requirements to roughly 9% to 13% for large banks (estimate, varies).
  • Breaching the buffer triggers the Maximum Distributable Amount, an automatic cap on dividends, buybacks, and bonuses, which is why banks hold a management buffer well above the minimum.
  • The LCR (minimum 100%) protects against 30-day liquidity runs; the leverage ratio (minimum 3%, higher for G-SIBs) is the unweighted backstop that RWA cannot game.
  • Real reporting runs through the FR Y-9C in the US and COREP / FINREP in the EU, enforced by the Fed, OCC, FDIC, ECB, EBA, and PRA, with stress tests like CCAR / DFAST feeding back into required capital.
  • Basel is not one global law: each jurisdiction implements it (CRR/CRD in the EU, agency rules in the US), and the US "endgame" calibration remained under negotiation into 2026.

Précédent

The regulators who can shut your bank down

Suivant

KYC, AML and the cost of dirty money