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Concept

The Supplementary Leverage Ratio (SLR) operates as a primary capital adequacy measure for large U.S. bank holding companies, fundamentally influencing their capacity to engage in market-making activities. It functions as a non-risk-weighted backstop to risk-based capital requirements, stipulating a minimum level of Tier 1 capital relative to a bank’s total leverage exposure. This framework treats all assets equally from a leverage perspective, assigning the same capital requirement to a U.S. Treasury security as it does to a significantly riskier asset. This risk-agnostic nature is a critical design feature, intended to prevent the excessive accumulation of leverage that characterized the 2008 financial crisis.

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The Mechanics of the Leverage Ratio

At its core, the SLR is calculated by dividing a bank’s Tier 1 capital ▴ its most loss-absorbing capital, comprising common equity and other qualifying instruments ▴ by its total leverage exposure (TLE). The TLE is a broad measure that includes all on-balance-sheet assets and many off-balance-sheet exposures, such as securities financing transactions (SFTs) like repurchase agreements (repos). For the largest, global systemically important banks (G-SIBs), the minimum SLR is set at 5 percent. When this ratio becomes the binding constraint on a bank’s activities, it can create powerful disincentives for holding low-risk, low-return assets, which are the bedrock of dealer market making.

The SLR’s risk-insensitive design directly impacts dealer balance sheets by making high-volume, low-risk activities, such as Treasury market intermediation, capital-intensive.
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Dealer Market Making as a Balance Sheet Intensive Operation

Dealer market making is an inherently balance-sheet-intensive business. Primary dealers, particularly the large bank-affiliated ones, provide liquidity to crucial markets like U.S. Treasuries by standing ready to buy and sell securities, thereby facilitating price discovery and smooth market functioning. To perform this role, they must hold inventories of securities and engage extensively in the repo market to finance these positions. Each of these activities expands the dealer’s balance sheet and, consequently, its TLE.

When the SLR is the binding capital constraint, every dollar of assets added to the balance sheet ▴ whether a Treasury bond or a corporate loan ▴ consumes a proportional amount of the bank’s capital. This dynamic creates a direct trade-off between a dealer’s ability to provide liquidity and its adherence to regulatory capital minimums.


Strategy

The strategic implications of the Supplementary Leverage Ratio for dealer market making are profound, creating a direct link between a bank’s regulatory capital position and its operational capacity in financial markets. When the SLR becomes a binding constraint, it forces a strategic reallocation of balance sheet resources away from activities that offer low returns relative to their contribution to total leverage exposure. This disproportionately affects market-making in safe assets like U.S. Treasuries, which are characterized by high volumes and thin margins.

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The Economic Calculus of a Binding SLR

For a dealer bank, every asset and off-balance-sheet commitment contributes to the denominator of the SLR calculation. The strategic challenge arises because the rule does not differentiate based on the asset’s risk profile. Consequently, a dealer must hold the same amount of Tier 1 capital against a U.S. Treasury security as it does for a more speculative asset.

This alters the risk-return calculation for market-making activities. The low returns generated from intermediating Treasury securities may not justify the capital consumption required under a binding SLR regime, leading dealers to strategically reduce their presence in these markets.

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Balance Sheet Optimization under Leverage Constraints

Faced with a binding SLR, dealer banks employ several strategies to optimize their balance sheets. These actions are designed to reduce total leverage exposure while preserving capital for higher-return activities. Common strategic responses include:

  • Inventory Reduction ▴ Dealers may reduce the size of their securities inventories, particularly in low-margin markets like U.S. Treasuries. This limits their ability to absorb large client orders and buffer market volatility.
  • Wider Bid-Ask Spreads ▴ To compensate for the higher capital cost of intermediation, dealers may widen their bid-ask spreads. This increases the cost for end-users to transact and is a direct measure of reduced market liquidity.
  • Reduced Repo Market Activity ▴ A significant portion of a dealer’s TLE comes from securities financing transactions. Dealers may pull back from repo market intermediation, which is crucial for financing client positions and overall market liquidity.
A binding SLR incentivizes dealers to prioritize higher-margin activities over the provision of liquidity in low-risk, foundational markets like U.S. Treasuries.
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Comparative Impact on Dealer Operations

The table below illustrates the disproportionate impact of a binding SLR on low-risk market-making activities compared to higher-risk, higher-return businesses. It assumes a simplified scenario for a bank with a 5% SLR requirement.

Table 1 ▴ Illustrative Impact of SLR on Different Banking Activities
Activity Asset Value (TLE Contribution) Required Tier 1 Capital (at 5% SLR) Typical Annual Return (Illustrative) Return on Required Capital
Treasury Market Making $1,000,000,000 $50,000,000 0.10% ($1,000,000) 2.0%
Corporate Lending $1,000,000,000 $50,000,000 4.00% ($40,000,000) 80.0%

This simplified comparison demonstrates that from a pure capital-return perspective under a binding SLR, the incentive is to allocate balance sheet capacity to higher-yielding assets, even if they carry more risk (which would be captured by risk-based capital rules, but not the SLR). This strategic pressure directly curtails a dealer’s willingness and ability to intermediate in the Treasury market.


Execution

The execution of dealer market-making strategies under the constraints of the Supplementary Leverage Ratio involves precise, tactical adjustments to trading operations and balance sheet management. These adjustments are a direct consequence of the ratio’s influence on the economics of intermediation, particularly in the U.S. Treasury market. When the SLR approaches its regulatory minimum, dealers must actively manage their total leverage exposure, which translates into tangible changes in market behavior and liquidity conditions.

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Operational Adjustments in Treasury Intermediation

The primary operational effect of a binding SLR is a reduction in the dealer’s capacity to warehouse risk and provide liquidity. This manifests in several ways during the execution of trading.

  1. Altered Quoting Behavior ▴ Dealers become more selective in the prices they quote. Bid-ask spreads widen to reflect the increased capital cost per trade. This is most pronounced during periods of market stress when the demand for dealer intermediation surges, precisely when their balance sheet capacity is most constrained.
  2. Reduced Position Sizing ▴ The size of the positions dealers are willing to take onto their books shrinks. This affects their ability to handle large block trades from institutional clients without causing significant market impact.
  3. Changes in Financing ▴ A dealer’s securities inventory is largely financed through the repo market. The SLR calculation includes these financing transactions, increasing TLE. Consequently, dealers may reduce their repo market activity, which not only constrains their own inventory but also reduces the availability of financing for other market participants, creating a systemic tightening of liquidity.
Temporary modifications to the SLR, such as the exemption for Treasuries and reserves in 2020-2021, have demonstrated a direct causal link between the regulation and dealer intermediation capacity.
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Quantitative Impact on Market Liquidity Metrics

The impact of SLR constraints can be observed in key market liquidity metrics. The table below provides a hypothetical scenario illustrating how a dealer’s quoting behavior might change as its SLR becomes more binding.

Table 2 ▴ Hypothetical Dealer Quoting Strategy vs. SLR Headroom
Dealer’s SLR Headroom (Actual SLR – 5% Minimum) Typical Bid-Ask Spread (10-Year Treasury Note) Maximum Quoted Size (in millions) Willingness to Absorb Client Flow
> 2.0% (Unconstrained) 0.25/32nds $500M High
1.0% – 2.0% (Monitoring) 0.50/32nds $250M Moderate
< 1.0% (Constrained) 0.75/32nds – 1.0/32nds $100M Low / Price-driven
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The Role of Regulatory Exemptions

The temporary exclusion of U.S. Treasury securities and central bank reserves from the TLE calculation between April 2020 and March 2021 provided a real-world experiment on the SLR’s impact. Research indicates that this relaxation of the constraint led to an increase in dealers’ Treasury trading activity, particularly among those dealers who were most constrained before the exemption. This event underscored the direct mechanical link between the SLR calculation and dealers’ ability to intermediate the Treasury market. The subsequent expiration of this relief has renewed focus on potential permanent reforms to the SLR to mitigate its disincentives for market making in safe assets.

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References

  • Bank Policy Institute. “What They Are Saying About Supplementary Leverage Ratio Reform.” BPI, April 10, 2025.
  • Cochran, Paul, et al. “Dealers’ Treasury Market Intermediation and the Supplementary Leverage Ratio.” FEDS Notes, Board of Governors of the Federal Reserve System, August 3, 2023.
  • Board of Governors of the Federal Reserve System. “Regulatory Capital Rule ▴ Modifications to the Enhanced Supplementary Leverage Ratio Standards for U.S. Global Systemically Impor.” Federal Reserve Board, June 25, 2025.
  • Bräuning, Falk, and Victoria Ivashina. “Evidence That Relaxing Dealers’ Risk Constraints Can Make the Treasury Market More Liquid.” Federal Reserve Bank of Boston, March 4, 2025.
  • Kohn, Donald. “Donald Kohn’s thoughts on supplementary leverage ratio reform.” The Brookings Institution, August 12, 2025.
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Reflection

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Systemic Resilience and Regulatory Design

The interaction between the Supplementary Leverage Ratio and dealer market-making capacity prompts a deeper reflection on the objectives of financial regulation. The SLR was conceived as a simple, robust backstop to prevent systemic risk from excessive leverage. Its very simplicity, however, creates unintended consequences for market structure and liquidity. The challenge lies in designing a regulatory framework that ensures bank solvency without impairing the vital function of market intermediation, especially in the government securities market that forms the bedrock of the global financial system.

The ongoing dialogue about calibrating the SLR highlights the perpetual tension between microprudential safety and macroeconomic stability. It forces us to consider how capital adequacy rules can be refined to be more intelligent, recognizing that not all leverage carries the same risk and that the provision of liquidity is a systemically critical function.

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Glossary

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Supplementary Leverage Ratio

Meaning ▴ The Supplementary Leverage Ratio (SLR) represents a core capital adequacy metric, calculating a banking organization's Tier 1 capital as a percentage of its total leverage exposure, without regard for risk weighting.
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Total Leverage Exposure

Meaning ▴ Total Leverage Exposure quantifies the aggregate notional value of all open leveraged positions across a portfolio, typically expressed in a standardized currency equivalent.
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Dealer Market Making

Meaning ▴ Dealer Market Making involves a financial institution consistently quoting both bid and ask prices for a specific asset, thereby facilitating two-way liquidity for clients.
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Leverage Exposure

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Dealer Market

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Balance Sheet

A bank-dealer's balance sheet is a regulated, client-serving inventory; a PTF's is a lean, proprietary engine for capital velocity.
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Regulatory Capital

Meaning ▴ Regulatory Capital represents the minimum amount of financial resources a regulated entity, such as a bank or brokerage, must hold to absorb potential losses from its operations and exposures, thereby safeguarding solvency and systemic stability.
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Supplementary Leverage

The SLR's risk-insensitivity has inadvertently constrained repo market liquidity and incentivized risk-shifting by financial institutions.
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Total Leverage

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Tier 1 Capital

Meaning ▴ Tier 1 Capital represents the foundational and most robust component of a financial institution's capital structure, designed to absorb losses without requiring the firm to cease operations.
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Market Liquidity

Meaning ▴ Market liquidity quantifies the ease and cost with which an asset can be converted into cash without significant price impact.
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Bid-Ask Spreads

Meaning ▴ The Bid-Ask Spread defines the differential between the highest price a buyer is willing to pay for an asset, known as the bid, and the lowest price a seller is willing to accept, known as the ask or offer.
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Market Intermediation

The Countercyclical Capital Buffer's influence on non-bank finance is indirect, necessitating a broader macroprudential framework to manage systemic risk.
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Repo Market

Meaning ▴ The Repo Market functions as a critical short-term funding mechanism, enabling participants to borrow cash against high-quality collateral, typically government securities, with an agreement to repurchase the collateral at a specified future date and price.
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Treasury Market

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U.s. Treasury Market

Meaning ▴ The U.S.
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Leverage Ratio

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Market Making

MiFID II contractually binds HFTs to provide liquidity, creating a system of mandated stability that allows for strategic, protocol-driven withdrawal only under declared "exceptional circumstances.".
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Financial Regulation

Meaning ▴ Financial Regulation comprises the codified rules, statutes, and directives issued by governmental or quasi-governmental authorities to govern the conduct of financial institutions, markets, and participants.
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Systemic Risk

Meaning ▴ Systemic risk denotes the potential for a localized failure within a financial system to propagate and trigger a cascade of subsequent failures across interconnected entities, leading to the collapse of the entire system.