The FDIC, Federal Reserve and OCC have proposed to extend the long-term debt and clean holding company portions of the Federal Reserve’s existing TLAC Rule for U.S. GSIBs and U.S IHCs of foreign GSIBs to all large banking organizations with $100 billion or more in total assets, with virtually no tailoring and only a few other amendments to the existing TLAC Rule. This client update compares the key provisions of the LTD Proposal to the Federal Reserve’s existing TLAC Rule.

Read the full update

If you have any questions regarding the matters covered in this publication, please reach out to any of the lawyers listed below or your usual Davis Polk contact.

This communication, which we believe may be of interest to our clients and friends of the firm, is for general information only. It is not a full analysis of the matters presented and should not be relied upon as legal advice. This may be considered attorney advertising in some jurisdictions. Please refer to the firm's privacy notice for further details.
Copy link to share post