In this report, we continue our 2021 forecasts, moving from our assessment of digital finance (see Client Report DIGITAL6) and asset-management regulation (see Client Report RECOURSE6) to an assessment of the U.S. capital and liquidity framework for large banks and FBOs.  While Fed thinking on these standards will remain unchanged due to personnel continuity into 2021, Janet Yellen’s presence as chair of the Financial Stability Oversight Council and shifts at the OCC and FDIC will move the needle to tougher standards, especially for the largest banks.  FBOs will also come under renewed pressure to comply with U.S. liquidity rules due to growing concerns about MMF-dependent funding strategies.

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