TLAC, the Long-Term Debt Requirement, and the Clean Holding Company Proposal

IFLR Webinar

12/17/2015 11:00 a.m. - 12:30 p.m. EDT

Capital Markets, Banking + Financial Services, and Financial Institutions + Financial Services

Anna T. Pinedo and Oliver I. Ireland


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Trevor Starer
(212) 336-4310

As 2015 draws to a close, regulators have issued a number of new requirements aimed at systemically important lenders. These include the FSB’s final TLAC principles for G-SIBs and the US Federal Reserve Board’s notice of proposed rulemaking regarding a long-term debt requirement, a TLAC requirement and a clean holding company requirement for US G-SIBs, and the intermediate holding companies of foreign (non-US) G-SIBs subject to an IHC requirement. Although consistent in their objectives, these all differ in certain important respects. The requirements will have broad impacts on the ways in which G-SIBs finance their operations. Given that banks are frequent debt issuers, the effects of these changes will impact the debt capital markets.

In this webinar we will discuss:

  • The FSB’s final TLAC principles;
  • The FRB’s proposed requirements;
  • The principal differences between the FSB’s and the FRB’s approach;
  • The planning required of G-SIBs in order to prepare to comply;
  • Potential effects for foreign banks subject to both regimes; and
  • Anticipated effect on how banks will fund going forward.


  • Todd Mahoney, UBS
  • Ahmet Yetis, UBS
  • Oliver Ireland, Morrison & Foerster
  • Anna Pinedo, Morrison & Foerster


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