We've already built what your Fed examiner will ask you about in 2027.

European banks have spent three years — and several hundred million euros — wiring CRR3 into their plumbing. Every one of those scars is now a transferable asset. Ezelman brings that EU implementation muscle to US Category I–IV banks preparing for Basel III Endgame, CCAR/DFAST recalibration, and the next wave of SR 11-7 model risk scrutiny.

July '25
US Final Rule
July '28
Full compliance
+9%
Agg. Cat I–IV RWA
3 yrs
EU head start

Your Big Four advisor is reading the same rule you are.

Every major US consulting firm is standing up an Endgame practice right now. They are hiring. They are training. They are writing points of view. That is fine. It is also three years behind the institutions that have been implementing the underlying Basel framework in Europe since 2023.

Ezelman is not betting on Endgame as a growth line. We have been living in its European twin — CRR3 — for three years. We know which design choices cost 40 bps of CET1 two years later. We know where the output floor actually bites. We know what the ECB and the EBA have settled on vs. what they have punted to RTS. That knowledge compresses 18 months of US programme risk into a phone call.

Already shipped in Europe

CRR3 · in production Jan 2027

  • Output floor calibration across mortgages, specialised lending, low-LGD corporates
  • SA-CR redensification at scale — we know the revolver-book surprises
  • IRB input-floor remediation (PD floors, LGD floors, A-IRB scope removal)
  • CCF re-bucketing on off-balance-sheet exposures
  • SA-CCR vs. IMM trade-off runs on 6 top-10 EU books
  • BA-CVA vs. SA-CVA decision frameworks
  • Parallel-run discipline Q1–Q3 2026 across FINREP/COREP reconciliations

Landing in the US

Basel III Endgame · phase-in to July 2028

  • "Expanded Risk-Based Approach" vs. standardised — the choice US banks are making now
  • Dual-stack CCAR recalibration against the new RWA numerator
  • Operational risk transition from AMA/standardised to the new Business Indicator method
  • Market-risk FRTB rollout — US banks are where EU banks were in 2022
  • SR 11-7 model risk re-platforming for the new capital models
  • Board-grade disclosure: Pillar 3 equivalents and 10-Q risk narrative
  • Regional-bank capital optimisation: this is where the ROE fight is

Three ways to start — none of them require a deck.

30-min diagnostic

Endgame readiness call

A Partner-led 30-minute review of where you sit on the 12 decisions that move CET1 the most. No slides, no follow-on sales motion. If we can help, we'll tell you. If we can't, we'll tell you who can.

3–4 week sprint

Parallel-run architecture review

We sit with your RWA engine team, walk your pilot CRR3/Endgame runs, and produce a 20-page review: design gaps, CET1 impact sensitivity, supervisor-facing narrative, and the six decisions you need to make before the next Board risk committee.

12-month mandate

Endgame programme embed

Senior partners on the ground, part-time or block-scheduled. Governance, design, execution and supervisory dialogue. Designed for US Category I–III institutions that want EU scar tissue without the EU overhead.

Book the 30-min call →
Endgame diagnostic — 30 minutes, no deck.EU scar tissue applied to US regulation.
HM
Hannan Mohammad · Founder & Managing Partner, Ezelman20+ years on the regulatory front line at European G-SIBs. Read the latest analysis on LinkedIn.