Certain large banks are tracked and labelled by several authorities as Systemically Important Financial Institutions (SIFIs), depending on the scale and the degree of influence they hold in global and domestic financial markets.

Since 2011, the Financial Stability Board (FSB) has published a list of global SIFIs (G-SIFIs),[1] while individual countries also maintain their own lists of Domestic Systemically Important Banks (D-SIBs), also known in Europe as "national SIFIs" (N-SIFIs). In addition, special lists of regional systemically important banks (R-SIBs) also exist. The European Central Bank has separate criteria to designate credit institutions as "significant" under the framework of European Banking Supervision.

Background

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-SIFIs and the economy of sovereign states, the Financial Stability Board (FSB) started to develop a method to identify G-SIFIs to which a set of stricter requirements would apply. The first publication of some leaked unofficial G-SIFI 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.[2][3][4] The first official version of the G-SIFI list was published by FSB in November 2011.[5] The established nomenclature G-SIFI was supplemented and in large part replaced by the idea of a Global Systemically Important Bank (G-SIB) and has ever since been updated each year in November.[6][7][8][9][10] This G-SIB list is the first one shown below.

All G-SIBs and D-SIBs with headquarters in the US and Europe are required each year to submit an updated emergency Resolution Plan to their Financial Supervision Authority.[11][12] Basel III also requires that all identified G-SIBs no later than March 2018, shall operate with a minimum total capital adequacy ratio comprising:[13]

  • Max. 2% Tier 2 capital (Subordinated capital).
  • 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.
  • Max. 1.5% Additional Tier 1 capital (Hybrid capital, i.e. Contingent Convertibles aka CoCos).

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.[14] 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.[15]

The second set of lists, further below, includes 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.[16]

In 2013, the EU also adopted a regulation to identify all Domestic SIBs within each member state of the European Economic Area (EEA), 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.[13]

Both Basel III and the EU regulation, 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.[13]

List of Global Systemically Important Banks (G-SIBs)

In the following table the background colours of each entry correspond to the continent in which they are headquartered.

Headquarters
  North America
  Europe
  Asia
Entity
TierCountercyclical Capital Buffer 2023(29) [17]2022(30) [18]2021(30)[19]2020(30)[20]2019(30)[21]  2018(29)[22]
53.5% (Empty)(Empty)(Empty)(Empty)(Empty)
42.5% Steady JP Morgan ChaseSteady JP Morgan ChaseIncrease JP Morgan Chase(Empty)Steady JP Morgan ChaseSteady JP Morgan Chase
32.0% Steady Bank of America
Steady Citigroup
Steady HSBC
Increase Bank of America
Steady Citigroup
Steady HSBC
Increase BNP Paribas
Steady Citigroup
Steady HSBC
Steady Citigroup
Steady HSBC
Decrease JP Morgan Chase
Steady Citigroup
Steady HSBC
Steady Citigroup
Steady Deutsche Bank
Steady HSBC
21.5% Increase Agricultural Bank of China
Steady Bank of China
Steady Barclays
Steady BNP Paribas
Increase China Construction Bank
Steady Deutsche Bank
Steady Goldman Sachs
Steady ICBC
Steady MUFG
Increase UBS
Steady Bank of China
Steady Barclays
Decrease BNP Paribas
Steady Deutsche Bank
Steady Goldman Sachs
Steady ICBC
Steady MUFG
Steady Bank of America
Steady Bank of China
Steady Barclays
Steady China Construction Bank
Steady Deutsche Bank
Increase Goldman Sachs
Steady ICBC
Steady MUFG
Steady Bank of America
Steady Bank of China
Steady Barclays
Steady BNP Paribas
Increase China Construction Bank
Steady Deutsche Bank
Steady ICBC
Steady MUFG
Steady Bank of America
Steady Bank of China
Steady Barclays
Steady BNP Paribas
Decrease Deutsche Bank
Steady Goldman Sachs
Steady ICBC
Steady MUFG
Steady Wells Fargo
Decrease Bank of America
Steady Bank of China
Steady Barclays
Steady BNP Paribas
Steady Goldman Sachs
Steady ICBC
Steady MUFG
Steady Wells Fargo
11.0% Increase Bank of Communications (BoCom)
Steady Bank of New York Mellon
Steady Groupe BPCE
Steady Crédit Agricole
Steady ING
Steady Mizuho FG
Steady Morgan Stanley
Steady Royal Bank of Canada
Steady Banco Santander
Steady Société Générale
Steady Standard Chartered
Steady State Street
Steady Sumitomo Mitsui
Steady Toronto-Dominion Bank
Steady Wells Fargo
Steady Agricultural Bank of China
Steady Bank of New York Mellon
Decrease China Construction Bank
Steady Credit Suisse
Steady Groupe BPCE
Steady Crédit Agricole
Steady ING
Steady Mizuho FG
Steady Morgan Stanley
Steady Royal Bank of Canada
Steady Banco Santander
Steady Société Générale
Steady Standard Chartered
Steady State Street
Steady Sumitomo Mitsui
Steady Toronto-Dominion Bank
Steady UBS
Steady UniCredit
Steady Wells Fargo
Steady Agricultural Bank of China
Steady Bank of New York Mellon
Steady Credit Suisse
Steady Groupe BPCE
Steady Crédit Agricole
Steady ING
Steady Mizuho FG
Steady Morgan Stanley
Steady Royal Bank of Canada
Steady Banco Santander
Steady Société Générale
Steady Standard Chartered
Steady State Street
Steady Sumitomo Mitsui
Steady Toronto-Dominion Bank
Steady UBS
Steady UniCredit
Steady Wells Fargo
Steady Agricultural Bank of China
Steady Bank of New York Mellon
Steady Credit Suisse
Decrease Goldman Sachs
Steady Groupe BPCE
Steady Crédit Agricole
Steady ING
Steady Mizuho FG
Steady Morgan Stanley
Steady Royal Bank of Canada
Steady Banco Santander
Steady Société Générale
Steady Standard Chartered
Steady State Street
Steady Sumitomo Mitsui
Steady Toronto-Dominion Bank
Steady UBS
Steady UniCredit
Decrease Wells Fargo
Steady Agricultural Bank of China
Steady Bank of New York Mellon
Steady China Construction Bank
Steady Credit Suisse
Steady Groupe BPCE
Steady Crédit Agricole
Steady ING
Steady Mizuho FG
Steady Morgan Stanley
Steady Royal Bank of Canada
Steady Banco Santander
Steady Société Générale
Steady Standard Chartered
Steady State Street
Steady Sumitomo Mitsui
Increase Toronto-Dominion Bank
Steady UBS
Steady UniCredit
Steady Agricultural Bank of China
Steady Bank of New York Mellon
Decrease China Construction Bank
Steady Credit Suisse
Increase Groupe BPCE
Steady Crédit Agricole
Steady ING
Steady Mizuho FG
Steady Morgan Stanley
Steady Royal Bank of Canada
Steady Banco Santander
Steady Société Générale
Steady Standard Chartered
Steady State Street
Steady Sumitomo Mitsui
Steady UBS
Steady UniCredit

List of Domestic Systemically Important Banks (D-SIBs)

D-SIBs in the US

For the United States, the D-SIB 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.[16] 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 the US.[23] The group of banks being stress tested was identical throughout 2009–2013, 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.[24]

All G-SIBs and D-SIBs with headquarters in the US 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.[25]

Legend
  Former D-SIB
List of all domestic systemically important banks in the US[26]
Entity Region HQ country Reporting currency FSB-G-SIB USA-ST HQ regulator Major exchange(s) IR Notes
Ally Financial Americas  US $, USD   2009– FSOC NYSE IR Formerly GMAC Inc.
American Express Americas  US $, USD   2009– FSOC NYSE IR  
Truist Financial Americas  US $, USD   2009– FSOC NYSE IR  
BMO Financial Corp. Americas  US $, USD   2014– FSOC IR Subsidiary of Bank of Montreal. Formerly Harris Financial Corp.
Capital One Financial Americas  US $, USD   2009– FSOC NYSE IR  
Comerica Americas  US $, USD   2014– FSOC NYSE IR  
Discover Financial Services Americas  US $, USD   2014– FSOC NYSE IR  
Fifth Third Bank Americas  US $, USD   2009– FSOC NASDAQ IR  
HSBC North America Holdings Americas  US $, USD   2014– FSOC IR Subsidiary of HSBC Holdings
Huntington Bancshares Americas  US $, USD   2014– FSOC NASDAQ IR  
KeyCorp Americas  US $, USD   2009– FSOC NYSE IR  
M&T Bank Americas  US $, USD   2014– FSOC NYSE IR  
MetLife Americas  US $, USD   2009‑12 FSOC NYSE IR Failed the stress test in 2012, and consequently sold its banking unit to GE Capital[27][28] and its mortgage servicing business to JPMorgan Chase.[29]
Northern Trust Americas  US $, USD   2014– FSOC NASDAQ IR  
PNC Financial Services Americas  US $, USD   2009– FSOC NYSE IR  
RBS Citizens Financial Group Americas  US $, USD   2014– FSOC NYSE IR
Regions Financial Americas  US $, USD   2009– FSOC NYSE IR  
Santander Holdings USA Americas  US $, USD   2014– FSOC NYSE IR Subsidiary of Santander Group
SunTrust Banks Americas  US $, USD   2009– FSOC NYSE IR Now Truist Financial through merger with BB&T.
U.S. Bancorp Americas  US $, USD   2009– FSOC NYSE IR  
UnionBanCal Americas  US $, USD   2014– FSOC IR Subsidiary of Mitsubishi UFJ FG
Zions Americas  US $, USD   2014– FSOC NYSE, NASDAQ IR  

D-SIBs within each of the EEA member states (both domestic and global)

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:

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 2015–2019, 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%.[13][30]

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.[31] 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.[32] 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
 Austria
 Belgium
 Bulgaria
 Croatia
 Cyprus[33] Bank of Cyprus

Hellenic Bank

RCB Bank

Eurobank Cyprus

 Czech Republic
 Denmark[30][34][35] Danske Bank
Nordea Denmark
Nykredit
Jyske Bank
Sydbank
DLR
 Estonia
 Finland
 France BNP Paribas
Crédit Agricole
Groupe BPCE
Société Générale
+ yet to be identified O-SIIs
 Germany Deutsche Bank
+ yet to be identified O-SIIs
 Greece[36] National Bank of Greece

Alpha Bank

Eurobank Ergasias Bank

 Hungary
 Iceland
 Ireland
 Italy[37] Unicredit Group
Intesa Sanpaolo
Monte dei Paschi di Siena
 Latvia
 Liechtenstein
 Lithuania
 Luxembourg
 Malta[38] HSBC Bank Malta
Bank of Valletta
MeDirect Bank Malta
 Netherlands[39] ING Bank
Rabobank
ABN Amro
SNS Bank
 Norway[40][41] DNB ASA
Nordea Bank Norge ASA
Kommunalbanken
 Poland
 Portugal
 Romania
 Slovakia
 Slovenia
 Spain[42] Banco Santander
BBVA
Caixabank
Banco Sabadell
 Sweden[43] Swedbank
Svenska Handelsbanken
SEB
Nordea
 United Kingdom[44] HSBC
Barclays
Nationwide Building Society
Standard Chartered Bank
Lloyds Banking Group
Santander UK
NatWest Group
The Co-operative Bank
Notes

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 to 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.[13]

Additional capital buffer requirements for the resolution phase

As of December 2013,[45][46][47] 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,[48] 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.[49] 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.[31]

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 US (both domestic and global)

Other states Identified SIBs
 Australia[50] Australia & New Zealand Banking Group
Commonwealth Bank
National Australia Bank
Westpac
 Canada[51] Bank of Montreal
Scotiabank
Canadian Imperial Bank of Commerce
National Bank of Canada
Royal Bank of Canada
Toronto-Dominion Bank
Desjardins Group
 China[52] Bank of China
ICBC
Agricultural Bank of China
China Construction Bank
Bank of Communications
China Merchants Bank
Industrial Bank
China CITIC Bank
Postal Savings Bank of China
Shanghai Pudong Development Bank
China Minsheng Bank
China Everbright Bank
Ping An Bank
Huaxia Bank
Bank of Ningbo
China Guangfa Bank
Bank of Jiangsu
Bank of Shanghai
Bank of Beijing
 Hong Kong[53] HSBC (Hong Kong)
Bank of China (Hong Kong)
Standard Chartered Hong Kong
Bank of East Asia
Hang Seng Bank
Industrial and Commercial Bank of China (Asia)
 India State Bank of India
ICICI Bank
HDFC Bank
 Indonesia [54] Bank Rakyat Indonesia
Bank Mandiri
Bank Central Asia
Bank Negara Indonesia
 Japan MUFG Bank
Mizuho FG
Sumitomo Mitsui
Nomura
Daiwa
+ yet to be identified O-SIIs
 Malaysia[55] Maybank
CIMB Bank
Public Bank
 Pakistan[56] National Bank of Pakistan
Habib Bank Limited
United Bank Limited
 Singapore[57] DBS Bank
OCBC Bank
UOB
Citibank
Maybank
Standard Chartered Bank
HSBC
  Switzerland[58][59] Credit Suisse
UBS
Zürcher Kantonalbank
Raiffeisen
PostFinance
 South Africa[60] Absa Bank
Standard Bank
FirstRand
Nedbank
Investec
Capitec Bank
 Taiwan[61] CTBC Bank
Cathay United Bank
Taipei Fubon Bank
Mega International Commercial Bank
Taiwan Cooperative Bank
First Bank

See also

References

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