In conjunction with a proposal from the Federal Reserve to tailor BHC standards, the Board, OCC, and FDIC have jointly proposed standards that would alter liquidity and capital rules for banks and BHCs above $100 billion in assets that are not now designated as global systemically-important banks in the U.S.  These changes were in part mandated by the 2018 Economic Growth, Regulatory Relief, and Consumer Protection Act (EGRRCPA), although opponents believe the law does not permit changes other than below $250 billion in assets.  The new approach leaves standards intact for GSIBs on grounds that their failure would have the largest and most devastating systemic impact and adds a small custody banking organization to a list of companies also subject to regulation akin to that demanded of the GSIBs.

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