“…To make this point, we primarily rely on the way in which GSIB regulation was phased in. Banks could not have anticipated the exact methodology for determining GSIB-surcharges ahead of our event date, the sample of GSIBs on which surcharges were ultimately imposed is not equivalent to our sample, and the first GSIB designation significantly pre-dates any documented activity to respond to GSIB-specific capital requirements (Goel et al, 2022).…”