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Regulatory Alert | November 2015

Regulatory Alert | November 2015

Federal Reserve Proposes TLAC and LTD Rule for GSIBs and IHCs


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Continuing Chair Janet Yellen’s stated goal of “ending the market perception that any banking firm is ‘too big to fail,’” the Federal Reserve Board (“Federal Reserve”) proposed a new rule on October 30, 2015, intended to improve the resiliency and resolvability of “covered BHCs” and “covered IHCs.” 

As proposed, covered BHCs would include U.S. entities identified as global systemically important bank holding companies (“GSIBs”) under the Federal Reserve’s risk- ased GSIB Capital Surcharge rule and covered IHCs would include the U.S. intermediate holding companies (“IHCs”) of global systemically important foreign banking organizations (“FBOs”) with $50 billion or more in U.S. nonbranch assets that must be formed under the Federal Reserve’s Enhanced Prudential Standards rule. 

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