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Regulation and Capital Adequacy
 9 Months Ended
Sep. 30, 2025
Regulation And Capital Adequacy [Abstract]  
Regulation and Capital Adequacy
Regulation and Capital Adequacy
The FRB is the primary regulator of Group Inc., a bank holding company under the U.S. Bank Holding Company Act of 1956 and a financial holding company under amendments to this Act. The firm is subject to consolidated regulatory capital requirements which are calculated in accordance with the regulations of the FRB (Capital Framework).
The capital requirements are expressed as risk-based capital and leverage ratios that compare measures of regulatory capital to risk-weighted assets (RWAs), average assets and off-balance sheet exposures. Failure to comply with these capital requirements would result in restrictions being imposed by the firm’s regulators and could limit the firm’s ability to repurchase shares, pay dividends and make certain discretionary compensation payments. The firm’s capital levels are also subject to qualitative judgments by the regulators about components of capital, risk weightings and other factors. Furthermore, certain of the firm’s subsidiaries are subject to separate regulations and capital requirements.
Capital Framework
The regulations under the Capital Framework are largely based on the Basel Committee on Banking Supervision’s (Basel Committee) capital framework for strengthening international capital standards (Basel III) and also implement certain provisions of the U.S. Dodd-Frank Wall Street Reform and Consumer Protection Act. Under the Capital Framework, the firm is an “Advanced approaches” banking organization and has been designated as a global systemically important bank (G-SIB).
The Capital Framework includes the minimum risk-based capital and the capital conservation buffer requirements. The buffer must consist entirely of capital that qualifies as Common Equity Tier 1 (CET1) capital.
The firm calculates its CET1 capital, Tier 1 capital and Total capital ratios in accordance with both the Standardized and Advanced Capital Rules. Each of the ratios calculated under the Standardized and Advanced Capital Rules must meet its respective capital requirements.
Under the Capital Framework, the firm is also subject to leverage requirements which consist of a minimum Tier 1 leverage ratio and a minimum supplementary leverage ratio (SLR), as well as the SLR buffer.
Consolidated Regulatory Capital Requirements
Risk-Based Capital Ratios. The table below presents the minimum, capital conservation buffer and total risk-based capital requirements.
As of
September
December
September
December
2025202420252024
 StandardizedAdvanced
Risk-based capital minimum requirements
CET1 capital ratio
4.5%4.5%4.5%4.5%
Tier 1 capital ratio
6.0%6.0%6.0%6.0%
Total capital ratio
8.0%8.0%8.0%8.0%
Capital conservation buffer requirements
G-SIB surcharge (Method 2)
3.0%3.0%3.0%3.0%
Stress capital buffer
6.1%6.2%N/AN/A
Fixed buffer
N/AN/A2.5%2.5%
Countercyclical capital buffer
0.0%0.0%0.0%0.0%
Total
9.1%9.2%5.5%5.5%
Total risk-based capital requirements
CET1 capital ratio13.6%13.7%10.0%10.0%
Tier 1 capital ratio15.1%15.2%11.5%11.5%
Total capital ratio17.1%17.2%13.5%13.5%
In the table above:
•The total risk-based capital requirements for each of the capital ratios consist of the required risk-based capital minimum and the capital conservation buffer requirements.

•The G-SIB surcharge is calculated using two methodologies (Method 1 and Method 2), the higher of which is reflected in the firm’s capital conservation buffer requirements. Method 1 is based on the Basel Committee’s methodology which, among other factors, relies upon measures of the size, interconnectedness, substitutability, complexity and cross-jurisdictional activities of each G-SIB. Method 2 uses similar inputs but includes a measure of reliance on short-term wholesale funding instead of substitutability. As of both September 2025 and December 2024, the G-SIB surcharge (Method 2) was higher and therefore was reflected in the capital conservation buffer requirements.
•In June 2025, the FRB disclosed that the firm’s stress capital buffer (SCB), from the 2024 Comprehensive Capital Analysis and Review (CCAR) stress test, has been reduced from 6.2% to 6.1%. The impact of this change would have been a reduction of 10 basis points to the December 2024 Standardized CET1 capital, Tier 1 capital and Total capital ratio requirements presented in the table above.
Additionally, based on the firm’s 2025 CCAR submission, the FRB has set the SCB for the firm at 3.4% beginning on October 1, 2025, which will decrease the firm’s Standardized requirement to 10.9% for the CET1 capital ratio, 12.4% for the Tier 1 capital ratio and 14.4% for the Total capital ratio. The SCB may be subject to further changes pending the finalization of the FRB’s outstanding proposal on SCB averaging.
The table below presents information about risk-based capital ratios.
$ in millionsStandardizedAdvanced
As of September 2025  
CET1 capital$103,769 $103,769 
Tier 1 capital$118,515 $118,515 
Tier 2 capital$14,209 $10,164 
Total capital$132,724 $128,679 
RWAs$723,406 $687,426 
CET1 capital ratio14.3%15.1%
Tier 1 capital ratio16.4%17.2%
Total capital ratio18.3%18.7%
As of December 2024  
CET1 capital$103,065 $103,065 
Tier 1 capital$115,647 $115,647 
Tier 2 capital$14,125 $10,164 
Total capital$129,772 $125,811 
RWAs$688,541 $674,812 
CET1 capital ratio15.0%15.3%
Tier 1 capital ratio16.8%17.1%
Total capital ratio18.8%18.6%
In the table above, the Standardized risk-based capital ratios as of September 2025 decreased compared with December 2024, reflecting an increase in Credit RWAs, partially offset by an increase in capital and a decrease in Market RWAs. The Advanced CET1 capital ratio as of September 2025 decreased compared with December 2024, reflecting an increase in Credit RWAs, partially offset by an increase in CET1 capital and a decrease in Operational and Market RWAs. The Advanced Tier 1 and Total capital ratios as of September 2025 were essentially unchanged compared with December 2024.
Leverage Ratios. The table below presents the leverage requirements.
As of
SeptemberDecember
 20252024
Tier 1 leverage ratio4.0%4.0%
SLR5.0%5.0%
In the table above, the SLR requirement of 5% includes a minimum of 3% and a 2% buffer applicable to G-SIBs.
The table below presents information about leverage ratios.
For the Three Months
 
Ended or as of
SeptemberDecember
$ in millions20252024
Tier 1 capital$118,515 $115,647 
Average adjusted total assets$1,799,376 $1,692,500 
Total leverage exposure
$2,265,348 $2,120,756 
Tier 1 leverage ratio6.6%6.8%
SLR5.2%5.5%
In the table above:
•Average adjusted total assets represents the average daily assets for the quarter adjusted for deductions from Tier 1 capital, and for the three months ended December 2024, also reflected the impact of Current Expected Credit Losses (CECL) transition.
•Total leverage exposure includes average adjusted total assets and the monthly average of off-balance sheet and other exposures, primarily consisting of derivatives, securities financing transactions, commitments and guarantees.
•Tier 1 leverage ratio is calculated as Tier 1 capital divided by average adjusted total assets.
•SLR is calculated as Tier 1 capital divided by total leverage exposure.
GS Bank USA
GS Bank USA is the firm’s primary U.S. bank subsidiary. GS Bank USA is a New York State-chartered bank and a member of the Federal Reserve System, is supervised and regulated by the FRB, the FDIC, the New York State Department of Financial Services (NYDFS) and the Consumer Financial Protection Bureau (CFPB), and is subject to regulatory capital requirements that are calculated under the Capital Framework. GS Bank USA is an “Advanced approaches” banking organization under the Capital Framework. The deposits of GS Bank USA are insured by the FDIC to the extent provided by law.

The Capital Framework includes the minimum risk-based capital and the capital conservation buffer requirements (consisting of a 2.5% buffer and the countercyclical capital buffer). The buffer must consist entirely of capital that qualifies as CET1 capital. In addition, the Capital Framework includes the leverage ratio requirement. GS Bank USA is required to calculate the CET1 capital, Tier 1 capital and Total capital ratios in accordance with both the Standardized and Advanced Capital Rules. The lower of each risk-based capital ratio under the Standardized and Advanced Capital Rules is the ratio against which GS Bank USA’s compliance with its risk-based capital requirements is assessed. In addition, under the regulatory framework for prompt corrective action applicable to GS Bank USA, in order to meet the quantitative requirements for a “well-capitalized” depository institution, GS Bank USA must also meet the “well-capitalized” requirements in the table below. GS Bank USA’s capital levels and prompt corrective action classification are also subject to qualitative judgments by the regulators about components of capital, risk weightings and other factors. Failure to comply with the capital requirements, including a breach of the buffers described below, would result in restrictions being imposed by the regulators.
The table below presents GS Bank USA’s risk-based capital, leverage and “well-capitalized” requirements.
As of
SeptemberDecemberSeptemberDecember
 2025202420252024
"Well-capitalized"
Requirements
Requirements
Risk-based capital requirements 
CET1 capital ratio7.0%7.0%6.5%6.5%
Tier 1 capital ratio8.5%8.5%8.0%8.0%
Total capital ratio10.5%10.5%10.0%10.0%
Leverage requirements 
Tier 1 leverage ratio4.0%4.0%5.0%5.0%
SLR3.0%3.0%6.0%6.0%
In the table above:
•The CET1 capital ratio requirement includes a minimum of 4.5%, the Tier 1 capital ratio requirement includes a minimum of 6.0% and the Total capital ratio requirement includes a minimum of 8.0%. These requirements also include the capital conservation buffer requirements consisting of a 2.5% buffer and the countercyclical capital buffer, which the FRB has set to zero percent.
•The “well-capitalized” requirements are the binding requirements for leverage ratios.

The table below presents information about GS Bank USA’s risk-based capital ratios.
$ in millionsStandardizedAdvanced
As of September 2025  
CET1 capital$64,251 $64,251 
Tier 1 capital$64,251 $64,251 
Tier 2 capital$4,454 $1,124 
Total capital$68,705 $65,375 
RWAs$404,962 $308,247 
CET1 capital ratio15.9%20.8%
Tier 1 capital ratio15.9%20.8%
Total capital ratio17.0%21.2%
As of December 2024  
CET1 capital$62,022 $62,022 
Tier 1 capital$62,022 $62,022 
Tier 2 capital$4,209 $955 
Total capital$66,231 $62,977 
RWAs$386,922 $284,624 
CET1 capital ratio16.0%21.8%
Tier 1 capital ratio16.0%21.8%
Total capital ratio17.1%22.1%
In the table above:
•The lower of the Standardized or Advanced ratio is the ratio against which GS Bank USA’s compliance with the capital requirements is assessed under the risk-based Capital Rules, and therefore, the Standardized ratios applied to GS Bank USA as of both September 2025 and December 2024.
•The Standardized risk-based capital ratios as of September 2025 were essentially unchanged compared with December 2024. The Advanced risk-based capital ratios as of September 2025 decreased compared with December 2024, primarily reflecting an increase in Credit RWAs, partially offset by an increase in capital and a decrease in Market RWAs.
The table below presents information about GS Bank USA’s leverage ratios.
For the Three Months
 
Ended or as of
SeptemberDecember
$ in millions20252024
Tier 1 capital$64,251 $62,022 
Average adjusted total assets$645,554 $565,513 
Total leverage exposure
$875,095 $775,170 
Tier 1 leverage ratio10.0%11.0%
SLR7.3%8.0%
In the table above:
•Average adjusted total assets represents the average daily assets for the quarter adjusted for deductions from Tier 1 capital, and for the three months ended December 2024, also reflected the impact of CECL transition.


•Total leverage exposure includes average adjusted total assets and the monthly average of off-balance sheet and other exposures, primarily consisting of derivatives, securities financing transactions, commitments and guarantees.
•Tier 1 leverage ratio is calculated as Tier 1 capital divided by average adjusted total assets.
•SLR is calculated as Tier 1 capital divided by total leverage exposure.
The FRB requires that GS Bank USA maintain cash reserves with the Federal Reserve. As of both September 2025 and December 2024, the reserve requirement ratio was zero percent. See Note 26 for further information about cash deposits held by the firm at the Federal Reserve.
GS Bank USA is a registered swap dealer with the CFTC and a registered security-based swap dealer with the SEC. As of both September 2025 and December 2024, GS Bank USA was subject to and in compliance with applicable capital requirements for swap dealers and security-based swap dealers.
Restrictions on Payments
Group Inc. may be limited in its ability to access capital held at certain subsidiaries as a result of regulatory, tax or other constraints. These limitations include provisions of applicable law and regulations and other regulatory restrictions that limit the ability of those subsidiaries to declare and pay dividends without prior regulatory approval. For example, the amount of dividends that may be paid by GS Bank USA are limited to the lesser of the amounts calculated under a recent earnings test and an undivided profits test.
In addition, subsidiaries not subject to separate regulatory capital requirements may hold capital to satisfy local tax and legal guidelines, rating agency requirements (for entities with assigned credit ratings) or internal policies, including policies concerning the minimum amount of capital a subsidiary should hold based on its underlying level of risk.
Group Inc.’s equity investment in subsidiaries was $144.77 billion as of September 2025 and $140.79 billion as of December 2024. The firm’s regulated subsidiaries were required to hold minimum equity capital of $110.98 billion as of September 2025 and $98.48 billion as of December 2024 to satisfy regulatory requirements.
Group Inc.’s capital invested in certain non-U.S. dollar functional currency subsidiaries is exposed to foreign exchange risk, substantially all of which is managed through a combination of non-U.S. dollar-denominated debt and derivatives. See Note 7 for information about the firm’s net investment hedges used to hedge this risk.