Fed’s Final TLAC Rule

Morrison & Foerster Briefing

19 Dec 2016 04:15 p.m. - 04:45 p.m. EST

Trevor Starer
(212) 336-4310

On December 15, 2016, the Federal Reserve Board will hold an open meeting to consider and approve the final rules relating to a long-term debt, total loss absorbing capacity (TLAC), and clean holding company requirement. The long-awaited final rules will have important effects for U.S. G-SIBs and for foreign banks that are G-SIBs and subject to an intermediate holding company requirement. Join us for an overview and our preliminary analysis.

We will provide an overview of:

  • The Fed’s final rules;
  • Principal differences between the proposed rules and the final rules;
  • Considerations for foreign banks subject to the rules;
  • An assessment of the U.S. internal TLAC requirement compared to the IHC requirement proposed by the European Commission; and
  • The anticipated effect of the Fed’s final rules on various financial products.


  • Oliver Ireland,
    Partner, Morrison & Foerster LLP

This will be an operator-assisted call; all lines will be muted, but we will provide for a Q&A.



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