Gibson Dunn explains Resolution Triumphs: Proposed U.S. TLAC and Long-Term Debt Requirements for G-SIBs

At an October 30th open meeting, the Board of Governors of the Federal Reserve System (Federal Reserve) approved a proposed rule (Proposed Rule) that would impose Total Loss Absorbing Capacity (TLAC) and long-term debt (LTD) requirements for globally significant banks (G-SIBs). In so doing, it anticipated by ten days the Financial Stability Board (FSB), which finalized its template for TLAC on November 9th. Although the Proposed Rule is consistent with important aspects of the FSB’s TLAC requirements, its LTD requirement is more onerous. In addition, the Proposed Rule would impose new “clean holding company” requirements on institutions subject … Read more

Gibson Dunn discusses OCC Proposed Guidelines for Heightened Governance Standards for Large US Banks and Their Boards

The Office of the Comptroller of the Currency (OCC) has issued for public comment proposed guidelines (Guidelines) to establish minimum standards for risk management governance at large insured national banks, insured federal savings associations, and insured branches of non-U.S. banks (Banks).[1] The proposed Guidelines would generally apply to any such institution that has average total consolidated assets of $50 billion or more, measured over the four most recent consecutive quarters.

The Guidelines are yet another step in what is becoming a codified corporate governance framework for banking organizations that are deemed systemically significant, like the enhanced prudential standards proposed by

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