CFA Institute Systemic Risk Council Writes in Support of Proposed Rules on Long-term Debt Requirements

On December 10, 2023, the Systemic Risk Council (the Council) offered its response to proposed rules of the Office of the Comptroller of the Currency, the Board of Governors of the Federal Reserve System, and the Federal Deposit Insurance Corporation that would require certain large depository institution holding companies, U.S. intermediate holding companies of foreign banking organizations, and certain insured depository institutions, to issue and maintain outstanding a minimum amount of long-term debt. The proposed rule would improve the resolvability of these banking organizations in case of failure, may reduce costs to the Deposit Insurance Fund, and mitigate financial stability and contagion risks by reducing the risk of loss to uninsured depositors. The Council supports the agencies’ proposed requirement that large regional banks must hold a minimum level of long-term debt to aid in their resolvability in the case of failure. The Council additionally supports other elements of this multi-agency rulemaking as agencies seek to improve the resolvability of these banking organizations in case of failure, reduce costs to the Deposit Insurance Fund, and decrease the probability that extraordinary support measures may be needed in the future by reducing financial stability and contagion risks associated with the risk of loss to uninsured depositors.

 

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