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.
† The March 2026 joint re-proposal (Federal Reserve, OCC, FDIC) is framed as broadly capital-neutral; the agencies' own impact analysis estimates a modest decrease in aggregate CET1 requirements of about 4.8% for Category I-II firms and 5.2% for Category III-IV firms, a reversal of the 2023 proposal's ~+9% aggregate uplift. The re-proposal contains no compliance or phase-in dates; these will be set in the final rule. Sitewide public-data policy: every figure on ezelman.com is either a public-source citation, an estimate with stated methodology, or a qualitative mandate outcome — full notes on Resources.
We have already implemented the European twin of Endgame. Three years of it.
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 a sound commercial response to the rule. It is also three years behind the institutions that have been implementing the underlying Basel framework in Europe since 2023 — which is where Ezelman has been sitting as a senior-only CRR3 and OSI specialist.
Ezelman is not betting on Endgame as a growth line. We have been living in its European twin — CRR3 — for multiple years. We know which design choices cost material basis points 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 several quarters of US programme risk into a phone call.
Already shipped in Europe
CRR3 · in production since Jan 2025
- 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 · compliance dates to be set in the final rule (none in the March 2026 re-proposal)
- "Expanded Risk-Based Approach" (mandatory for Category I–II) vs. the revised standardised approach, with ERBA optional for Category III–IV — 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
From EU production today to US compliance under the final rule.
Four anchored milestones — the same compression EU banks have been running since 2023 is what US Cat I–IV institutions are about to repeat. The advantage is being able to walk through it with someone who has already lived each milestone.
Three ways to start — none of them require a deck.
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.
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.
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.