One, but certainly not the only, way to do this would be for the enhanced supplemental leverage ratio to be 1 percent for the firms with a 1 percent to 1-½ percent riskbased surcharge, 1-½ percent for those with a 2 percent or 2-½ percent risk-based surcharge, and 2 percent for those at 3 percent or above.
An alternative approach to mitigating the distortionary effects of the leverage ratio requirements is to exclude certain “riskless” assets from the denominator.