As described in section 601, the FCA allows bank holding companies and subsidiaries to simultaneously choose a regulatory off-ramp if the holding company has an average leverage ratio, meaning equity-to-total consolidated assets, of at least 10 percent.
Choice 2.0, Title VI vs. The Hoenig Proposal
StephenMatteoMiller
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Conceptually consistent with the “Pre-Commitment Approach” raised during the 1990s with respect to capital cover for bank derivatives activities except that the yardstick in the CHOICE Act is defined by a regulatory parameter (the leverage ratio) rather than internal models.

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