List of systemically important banks
Certain large banks are tracked and labelled by several authorities as systemically important financial institutions, depending on the scale and the degree of influence they hold in global and domestic financial markets. Since 2011, the Financial Stability Board has published a list of global systemically important banks (G-SIBs), while individual countries also maintain their own lists of domestic systemically important banks (D-SIBs), also known in Europe as "national SIFIs". In addition, special lists of regional systemically important banks (R-SIBs) also exist.
In 2009, as a regulatory response to the revealed vulnerability of the banking sector in the financial crisis of 2007–08, and attempting to come up with a solution to solve the "too big to fail" interdependence between G-SIBs and the economy of sovereign states, the Financial Stability Board (FSB) started to develop a method to identify G-SIBs to whom a set of stricter requirements would apply. The first publication of some leaked unofficial G-SIB lists, during a time when the FSB identification method was still being tested and subject for subsequent adjustments, took place in November 2009 and November 2010. The first official version of the G-SIB list was published by FSB in November 2011, and has ever since been updated each year in November. This G-SIB list is the first one shown below.
All G-SIBs and D-SIBs with headquarters in USA and Europe, are required each year to submit an updated emergency Resolution Plan to their Financial Supervision Authority. Basel III also requires that all identified G-SIBs no later than March 2018, shall operate with a minimum total capital adequacy ratio comprising:
- Max. 2% Tier 2 capital (Subordinated capital).
- Max. 1.5% Additional Tier 1 capital (Hybrid capital, i.e. Contingent Convertibles aka CoCos).
- Min. 8.0%/8.5%/9.0%/9.5%/10.5% high quality Tier 1 capital (Common Equity Tier 1 capital).*
This requirement towards G-SIBs depend on an indicator-based measure of size, interconnectedness, complexity, non-substitutibility and global reach, elevating it to be 1.0% or 1.5% or 2.0% or 2.5% or 3.5% higher, compared to the similar Basel III capital requirement at 7% towards banks not contained on the list.
In addition to the Basel III Capital Adequacy Ratio requirements, on November 10, 2014 the FSB issued a consultative document that defines a global standard for minimum amounts of Total Loss Absorbency Capacity ("TLAC") to be held by G-SIBs. The TLAC are amounts to be held in addition to the Capital Adequacy Ratio requirements, by G-SIBs. This proposal was under consultation until February 2, 2015, when the requirement was finalized. The FSB issued the final minimum total loss-absorbing capacity (TLAC) standard for 30 G-SIBs 9 November 2015.
The second list, further below, include all those financial institutions having been identified as systemically important by a national regulator, the so-called D-SIBs. For the United States, this list include all those financial institutions not being big enough for G-SIB status, but still with high enough domestic systemically importance making them subject to the most stringent annual Stress Test (USA-ST) by the Federal Reserve.
In 2013, the EU also adopted a regulation to identify all Domestic SIBs within each EEA member state, which after a phase-in during 2015–18, then shall comply with some even higher total capital adequacy ratio requirements – in accordance with how systemically important they are. Beside of expanding the SIB list, so that it now both include G-SIBs and D-SIBs, the regulation also ensure that all European G-SIBs (with headquarters in one of the EEA member states), will face some higher capital adequacy ratio requirements compared to those required by the FSB.
Both Basel III and the EU regulation, in addition also introduced a potential counter-cyclical capital ratio buffer, which can be enforced by national authorities on top of the noted total capital adequacy ratios, with demands of up till 2.5% extra Common Equity Tier 1 capital towards all financial institutions (incl. SIBs), during years where the total lending in the specific nation starts to grow faster than the national GDP.
List of Global Systemically Important Banks (G-SIBs)Edit
|Entity||Region||HQ country||Reporting currency||FSB-G-SIB||USA-ST||HQ regulator||Notes||Total capital ratio requirement|
(% of RWA)[a]
|Mizuho FG||Asia||Japan||¥, Yen||2011–||FSAj||11.5% (CET1=min.8%)|
|Sumitomo Mitsui||Asia||Japan||¥, Yen||2011–||FSAj||11.5% (CET1=min.8%)|
|Mitsubishi UFJ FG||Asia||Japan||¥, Yen||2011–||FSAj||12.0% (CET1=min.8.5%)|
|Bank of China||Asia||China||元, Renminbi||2011–||CBIRC||Majority state-owned||11.5% (CET1=min.8%)|
|ICBC||Asia||China||元, Renminbi||2013–||CBIRC||Majority state-owned||11.5% (CET1=min.8%)|
|Agricultural Bank of China||Asia||China||元, Renminbi||2014–||CBIRC||Majority state-owned||11.5% (CET1=min.8%)|
|China Construction Bank||Asia||China||元, Renminbi||2015–||CBIRC||Majority state-owned||11.5% (CET1=min.8%)|
|Dexia Group||EMEA||Belgium||€, Euro||2011||FSMA||Underwent resolution October 2011. Dexia Belgium was split off to form Belfius, while remaining part of the group was left to be liquidated.||-|
|BNP Paribas||EMEA||France||€, Euro||2011–||AMF||12.5% (CET1=min.9%)|
|Crédit Agricole||EMEA||France||€, Euro||2011–||AMF||11.5% (CET1=min.8%)|
|Groupe BPCE||EMEA||France||€, Euro||2011–2016, 2018||AMF||10.5% (CET1=min.7%)|
|Société Générale||EMEA||France||€, Euro||2011–||AMF||11.5% (CET1=min.8%)|
|Commerzbank||EMEA||Germany||€, Euro||2011||BaFin||Removed due to declining systemic importance||10.5% (CET1=min.7%)|
|Deutsche Bank||EMEA||Germany||€, Euro||2011–||BaFin||12.5% (CET1=min.9%)|
|Unicredit Group||EMEA||Italy||€, Euro||2011–||CONSOB||11.5% (CET1=min.8%)|
|ING Bank||EMEA||Netherlands||€, Euro||2011–||DNB||11.5% (CET1=min.8%)|
|Banco Bilbao Vizcaya Argentaria||EMEA||Spain||€, Euro||2012–2015||BdE||Removed due to declining systemic importance||10.5% (CET1=min.7%)|
|Santander||EMEA||Spain||€, Euro||2011–||BdE||11.5% (CET1=min.8%)|
|Nordea||EMEA||Finland||€, Euro||2011–||FIN-FSA||Removed due to declining systemic importance||11.5% (CET1=min.8%)|
|Credit Suisse||EMEA||Switzerland||Fr, Swiss franc||2011–||FINMA||12.0% (CET1=min.8.5%)|
|UBS||EMEA||Switzerland||Fr, Swiss franc||2011–||FINMA||11.5% (CET1=min.8%)|
|Royal Bank of Scotland||EMEA||United Kingdom||£, GBP||2011–2018||PRA||Removed due to declining systemic importance||12.0% (CET1=min.8.5%)|
|Barclays||EMEA||United Kingdom||£, GBP||2011–||PRA||12.5% (CET1=min.9%)|
|HSBC||EMEA||United Kingdom||$, USD||2011–||PRA||13.0% (CET1=min.9.5%)|
|Lloyds Banking Group||EMEA||United Kingdom||£, GBP||2011||PRA||Removed due to declining systemic importance||10.5% (CET1=min.7%)|
|Standard Chartered||EMEA||United Kingdom||$, USD||2012–||PRA||11.5% (CET1=min.8%)|
|Royal Bank of Canada||Americas||Canada||$, CAD||2017–||OSFI||11.5% (CET1=min.8%)|
|Bank of America||Americas||United States||$, USD||2011–||2009–||FSOC||12.0% (CET1=min.8.5%)|
|Bank of New York Mellon||Americas||United States||$, USD||2011–||2009–||FSOC||11.5% (CET1=min.8%)|
|Citigroup||Americas||United States||$, USD||2011–||2009–||FSOC||12.5% (CET1=min.9%)|
|Goldman Sachs||Americas||United States||$, USD||2011–||2009–||FSOC||12.0% (CET1=min.8.5%)|
|JP Morgan Chase||Americas||United States||$, USD||2011–||2009–||FSOC||13.0% (CET1=min.9.5%)|
|Morgan Stanley||Americas||United States||$, USD||2011–||2009–||FSOC||12.0% (CET1=min.8.5%)|
|State Street||Americas||United States||$, USD||2011–||2009–||FSOC||11.5% (CET1=min.8%)|
|Wells Fargo||Americas||United States||$, USD||2011–||2009–||FSOC||11.5% (CET1=min.8%)|
- The listed minimum capital ratios have been defined by FSB, and apply fully towards the G-SIBs as per March 2018. Each country regulator is allowed to set stricter ratios than the minimum FSB requirement ratio, and in most cases have done so. The actual capital ratio requirements imposed by the bank's HQ country can be found in the supplemental D-SIB list.
List of Domestic Systemically Important Banks (D-SIBs)Edit
D-SIBs in USAEdit
For the United States, the D-SIB list include those financial institutions not being big enough for G-SIB status, but still with high enough domestic systemically importance making them subject to the most stringent annual Stress Test (USA-ST) by the Federal Reserve. Strictly speaking, the Financial Stability Oversight Council (FSOC) does not designate any banks or bank holding companies as systemically important, but the Dodd-Frank Act in its terms on the statute imposes heightened supervision standards (including being subject to the annual USA Stress Test) on any bank holding company with a larger than $50 billion balance sheet. Despite the lack of any official D-SIB designation, the banks being subject to the USA Stress Test can be considered to be D-SIBs in USA. The group of banks being stress tested was identical throughout 2009-13, except for MetLife Bank ceasing its banking and mortgage lending activities in 2012 - and therefore subsequently leaving the group of supervised entities. In 2014 the stress test was expanded from 18 to 30 banks, as a result of a phase-in of the provisions of the Board's Dodd-Frank Act stress test rules, only making the additional 12 entities subject to this stress test starting from 2014.
All G-SIBs and D-SIBs with headquarters in USA are not only required to comply with some stricter capital ratio requirements but also required to submit an updated emergency Resolution Plan each year to the Board of Governors of the Federal Reserve System.
|Entity||Region||HQ country||Reporting currency||FSB-G-SIB||USA-ST||HQ regulator||Major exchange(s)||IR||Notes||Total capital ratio requirement|
(% of RWA)
|Ally Financial||Americas||USA||$, USD||2009–||FSOC||NYSE||IR||Formerly GMAC Inc.|
|American Express||Americas||USA||$, USD||2009–||FSOC||NYSE||IR|
|BBVA Compass||Americas||USA||$, USD||2014–||FSOC||IR||Subsidiary of BBVA|
|BMO Financial Corp.||Americas||USA||$, USD||2014–||FSOC||IR||Subsidiary of Bank of Montreal. Formerly Harris Financial Corp.|
|Capital One Financial||Americas||USA||$, USD||2009–||FSOC||NYSE||IR|
|Discover Financial Services||Americas||USA||$, USD||2014–||FSOC||NYSE||IR|
|Fifth Third Bank||Americas||USA||$, USD||2009–||FSOC||NASDAQ||IR|
|HSBC North America Holdings||Americas||USA||$, USD||2014–||FSOC||IR||Subsidiary of HSBC Holdings|
|Huntington Bancshares||Americas||USA||$, USD||2014–||FSOC||NASDAQ||IR|
|M&T Bank||Americas||USA||$, USD||2014–||FSOC||NYSE||IR|
|MetLife||Americas||USA||$, USD||2009‑12||FSOC||NYSE||IR||Failed the stress test in 2012, and consequently sold its banking unit to GE Capital and its mortgage servicing business to JPMorgan Chase.||-|
|Northern Trust||Americas||USA||$, USD||2014–||FSOC||NASDAQ||IR|
|PNC Financial Services||Americas||USA||$, USD||2009–||FSOC||NYSE||IR|
|RBS Citizens Financial Group||Americas||USA||$, USD||2014–||FSOC||NYSE||IR||Subsidiary of Royal Bank of Scotland|
|Regions Financial||Americas||USA||$, USD||2009–||FSOC||NYSE||IR|
|Santander Holdings USA||Americas||USA||$, USD||2014–||FSOC||NYSE||IR||Subsidiary of Santander Group|
|SunTrust Banks||Americas||USA||$, USD||2009–||FSOC||NYSE||IR|
|U.S. Bancorp||Americas||USA||$, USD||2009–||FSOC||NYSE||IR|
|UnionBanCal||Americas||USA||$, USD||2014–||FSOC||IR||Subsidiary of Mitsubishi UFJ FG|
|Zions||Americas||USA||$, USD||2014–||FSOC||NYSE, NASDAQ||IR|
D-SIBs within each of the EEA member states (both domestic and global)Edit
In 2013 a new SIB regulation was formulated and adopted by the European Union, which outlined the responsibility for each EU member state and all of the three other EEA member states, to compose a list of all their domestic SIBs (with the term including not only ordinary banks - but also credit institutions and investment firms), and implement some new total capital ratio requirements towards these identified D-SIBs. The total capital ratio requirements towards D-SIBs, will be stricter than the minimum 10.5% required by Basel III towards all normal sized financial institutions, which comprise a requirement of:
- max. 2% Tier 2 capital (Subordinated capital).
- max. 1.5% Additional Tier 1 capital (Hybrid capital, i.e. Contingent Convertibles aka CoCos).
- min. 7% high quality Tier 1 capital (Common Equity Tier 1 capital).
The new stricter EU regulated capital requirements, applying towards all credit institutions or investment firms identified as being a D-SIB, basically adds further high quality Common Equity Tier 1 capital buffers on top of the above 10.5% Basel III minimum capital requirement, to be phased in during 2015–19, with full effect for the calendar year 2019. In addition, the new EU rules also requires all instruments recognised in the Additional Tier 1 capital of any credit institution or investment firm to be Contingent Convertibles with the attached clause, that it automatically will be either written down or converted into Common Equity Tier 1 instruments if the Common Equity Tier 1 capital ratio of the institution at any point of time falls below 5.125%.
Each national SIB list of the EEA Member States include: The already identified G-SIBs with headquarters in the concerned state, and the Other Systemically Important Institutions (O-SII; which include R-SIBs and D-SIBs) with headquarters/branches in the concerned state - to be identified at the latest on 31 December 2015. The European Banking Authority has published some mandatory guidelines on how the O-SIIs shall be identified in each EEA Member State, which will take effect on 1 January 2015. All identified SIBs in the list below are subject to the new elevated capital ratio requirements, which can be introduced immediately (as in Sweden) or phased-in during 2015-2019 (as in Denmark).
|EEA member states||Identified SIBs||Total capital ratio requirement|
(CET1+AT1+T2) in 2019
(% of RWA)
|Denmark||Danske Bank||13.5%+IRP (CET1=min.10% + AT1/T2=max.3.5%+IRP)[a]|
|Nordea Denmark||12.5%+IRP (CET1=min.9% + AT1/T2=max.3.5%+IRP)[a]|
|Nykredit||12.5%+IRP (CET1=min.9% + AT1/T2=max.3.5%+IRP)[a]|
|Jyske Bank||12.0%+IRP (CET1=min.8.5% + AT1/T2=max.3.5%+IRP)[a]|
|Sydbank||11.5%+IRP (CET1=min.8% + AT1/T2=max.3.5%+IRP)[a]|
|DLR||11.5%+IRP (CET1=min.8% + AT1/T2=max.3.5%+IRP)[a]|
|+ yet to be identified O-SIIs|
|+ yet to be identified O-SIIs|
|Monte dei Paschi di Siena|
|Norway||DNB ASA||16.5%+IRP (CET1=min.13% + AT1/T2=max.3.5%+IRP)[b]|
|Nordea Bank Norge ASA||16.5%+IRP (CET1=min.13% + AT1/T2=max.3.5%+IRP)[b]|
|Kommunalbanken||16.5%+IRP (CET1=min.13% + AT1/T2=max.3.5%+IRP)[b]|
|Spain||Banco Santander||G-SII and O-SII, 1% buffer|
|BBVA||O-SII, 0.75% buffer|
|Caixabank||O-SII, 0.25% buffer|
|Bankia||O-SII, 0.25% buffer|
|Banco Sabadell||O-SII, 0.25% buffer|
|Sweden||Swedbank||24.3% (CET1=min.19.0% + AT1/T2=max.5.3%)[c]|
|Svenska Handelsbanken||22.5% (CET1=min.17.5% + AT1/T2=max.5.0%)[c]|
|SEB||19.9% (CET1=min.15.4% + AT1/T2=max.4.5%)[c]|
|Nordea||19.0% (CET1=min.14.7% + AT1/T2=max.4.3%)[c]|
|Nationwide Building Society|
|Standard Chartered Bank|
|Lloyds Banking Group|
|Royal Bank of Scotland|
|The Co-operative Bank|
- IRP is an abbreviation of Individual Risk Premium (also known as the "Pillar 2 risk buffer"). For Denmark's seven SIBs, it was equal to a little less than 2% in average - when measured in 2013. The exact IRP figure shall each year be recalculated individually for each financial institution, by the national supervisor. The financial institution BRFkredit was selected to be a SIB in October 2013, being required to respect a total capital ratio of 11.5%+IRP in 2019, but was bought and became an integrated part of Jyske Bank on 30 April 2014 - meaning that it will no longer be subject to comply with the specific SIB-requirement as an independent entity.
- The CET1 requirement is phased-in, to be min.12% per 1 July 2015 and min.13% per 1 July 2016 onwards, and this requirement include a counter-cyclical capital ratio buffer currently activated to be 1% starting from 1 July 2015 onwards - but subject to potential later adjustment at the discretion of the Financial Supervisory Authority after its quarterly reassessment of the cyclical trends. In addition to the CET1-requirement an amount of max.3.5% AT1/T2 will be required in pillar 1 - so that the total capital buffer is min.16.5%+IRP per 1 July 2016. IRP is an abbreviation of Individual Risk Premium (also known as the "Pillar 2 risk buffer"), and is currently not published by the Norwegian FSA to the public - although the Norwegian Ministry of Finance recently asked the FSA to consider start publishing these figures for each institution in 2015. The IRP figures are in all circumstances recalculated each year by the FSA, based on some updated individual risk assessments.
- The capital requirements will apply in full for the four Swedish SIBs already from 1 January 2015. The noted total capital ratio's include each institutions Individual Risk Premium (also known as the "Pillar 2 risk buffer"), calculated on basis of their latest asset review in Q2-2014. The ratios also include an additional counter-cyclical capital ratio buffer of 1%, being required by the Financial Supervisory Authority to be met at the latest on 13 September 2015 - with a weight proportionally to the share of the institutions credit exposures in the cyclical affected sectors, meaning it has the following seize for the four SIBs (as per their exposures at the end of Q2-2014): Handelsbanken=0.49%, Nordea=0.19%, SEB=0.34%, Swedbank=0.57%.
In addition to the total capital ratio requirements noted above, each EEA member state will – as regulated by CRD4 – be allowed also to introduce counter-cyclical capital ratio buffers of up till 2.5% extra Common Equity Tier 1 capital, applying for all financial institutions (incl. SIBs) at the national level, if their national statistics measure the total lending to grow faster than the national GDP.
- Additional capital buffer requirements for the resolution phase
As of December 2013, the EU institutions also started the technical process to approve a new Bank Recovery and Resolution Directive, with entry into force on 1 January 2015, which also outlined the requirement of an extra crisis-management capital buffer, referred to as Minimum Requirement for own funds and Eligible Liabilities (MREL), to be decided by resolution authorities on a case by case basis. The directive so far did not quantify or specify minimum standards for how big the MREL needs to be. MREL aims to ensure that all firms have adequate total loss-absorbing capacity to be used in a possible resolution phase, including sufficient liabilities that could credibly be exposed to loss in resolution. All EU banks and investment firms will be subject to the MREL requirement, which will be set depending on firm specific risk assessments, from January 2016 at the latest. Separately, the FSB is also working on a proposal on Gone-concern Loss-Absorbing Capacity (GLAC) — such as long-term bonded debt — that will apply for G-SIBs. By ensuring that there are a sufficient amount of liabilities available to be bailed in at the point of resolution, GLAC will complement the MREL requirement.
MREL and GLAC are treated (just like leverage ratio requirements), as separate requirements from the total capital ratio requirement.
D-SIBs situated outside EEA or USA (both domestic and global)Edit
|Other states||Identified SIBs||Total capital ratio requirement|
(CET1+AT1+T2) in 2019
(% of RWA)
|Australia||Australia and New Zealand Banking Group||11.5%+IRP (CET1=min.8% + AT1/T2=max.3.5% + IRP)[a]|
|Commonwealth Bank of Australia||11.5%+IRP (CET1=min.8% + AT1/T2=max.3.5% + IRP)[a]|
|National Australia Bank||11.5%+IRP (CET1=min.8% + AT1/T2=max.3.5% + IRP)[a]|
|Westpac Banking Corporation||11.5%+IRP (CET1=min.8% + AT1/T2=max.3.5% + IRP)[a]|
|Canada||Bank of Montreal||11.5%+IRP (CET1=min.8% + AT1/T2=max.3.5% + IRP)[b]|
|Bank of Nova Scotia||11.5%+IRP (CET1=min.8% + AT1/T2=max.3.5% + IRP)[b]|
|Canadian Imperial Bank of Commerce||11.5%+IRP (CET1=min.8% + AT1/T2=max.3.5% + IRP)[b]|
|National Bank of Canada||11.5%+IRP (CET1=min.8% + AT1/T2=max.3.5% + IRP)[b]|
|Royal Bank of Canada||11.5%+IRP (CET1=min.8% + AT1/T2=max.3.5% + IRP)[b]|
|Toronto-Dominion Bank||11.5%+IRP (CET1=min.8% + AT1/T2=max.3.5% + IRP)[b]|
|Desjardins Group||11.5%+IRP (CET1=min.8% + AT1/T2=max.3.5% + IRP)[b]|
|Hong Kong||The Hongkong and Shanghai Banking Corporation||??% (???)|
|Bank of China (Hong Kong)||??% (???)|
|Hang Seng Bank||??% (???)|
|Bank of East Asia||??% (???)|
|Industrial and Commercial Bank of China (Asia)||??% (???)|
|Standard Chartered Hong Kong||??% (???)|
|China||Bank of China||??% (???)|
|Agricultural Bank of China||??% (???)|
|+ yet to be identified O-SIIs||??% (???)|
|Japan||Mitsubishi UFJ FG||??% (???)|
|Mizuho FG||??% (???)|
|Sumitomo Mitsui||??% (???)|
|+ yet to be identified O-SIIs||??% (???)|
|Switzerland||Credit Suisse||19% (CET1=min.10% and AT1/T2 cocos=max.9%)[c]|
|UBS||19% (CET1=min.10% and AT1/T2 cocos=max.9%)[c]|
|Zürcher Kantonalbank||??% (???)|
- The additional D-SIB buffer of 1% CET1, as well as the new capital reservation buffer of 2.5% CET1, will both be required without any phase-in, meaning that both the CET1 requirement and the noted total capital ratio requirement will apply in full starting from 1 Jan 2016. The noted additional IRP, is an abbreviation of Individual Risk Premium (also known as the "Pillar 2 risk buffer"), and is subject for annual recalculation of the FSA - based on some updated individual risk assessments. In case needed, an additional counter-cyclical capital ratio buffer ranging from 0-2.5% CET1, can also be activated at the discretion of the Financial Supervisory Authority after its quarterly reassessment of the cyclical trends, starting from 1 Jan 2016.
- The additional D-SIB buffer of 1% CET1 will be required starting from 1 Jan 2016, but the capital reservation buffer (equal to 2.5% CET1 in 2019) will be phased-in over four years, meaning the minimum CET1 capital requirement will be 6.125% in 2016, then 6.75% in 2017, then 7.375% in 2018 and finally 8% in 2019. In case needed, an additional counter-cyclical capital ratio buffer ranging from 0-2.5% CET1, can also be activated at the discretion of the Financial Supervisory Authority after its quarterly reassessment of the cyclical trends. In addition to the CET1-requirement an amount of max.3.5% AT1/T2 will be required in pillar 1 - so that the total capital buffer is min.11.5%+IRP in 2019. IRP is an abbreviation of Individual Risk Premium (also known as the "Pillar 2 risk buffer"), and is subject for annual recalculation of the FSA - based on some updated individual risk assessments. Beside of the six entities being designated to be Canadian SIBs, the entity Desjardins Group has been designated as systemically important for the province of Quebec, and is required to comply with the same set of requirements as the ordinary D-SIBs.
- On top of the noted total capital ratio, a temporary counter-cyclical capital ratio buffer of up till 2.5% (of the total risk-weighet assets) extra amount of CET1, can also be enforced. The Swiss authorities have - by effect since 30 September 2013 - demanded the banks to increase their CET1 amount with 1% extra of their risk-weighted residential mortgage loan positions.
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