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Last Updated: April 22, 2024

Long-Term Debt Requirements for Large Bank Holding Companies, Certain Intermediate Holding Companies of Foreign Banking Organizations, and Large Insured Depository Institutions
12 CFR Parts 324 and 374 RIN 3064–AF86
Notice of proposed rulemaking with request for public comment

88 FR 64524
Comment Period End: November 30, 2023
Extended Comment Period End: January 16, 2024

Summary: The Federal Deposit Insurance Corporation, Board of Governors of the Federal Reserve System (Board), and Office of the Comptroller of the Currency are proposing a rule that would require certain large banks to have outstanding a certain amount of long-term debt. This debt could make it easier to resolve these banks if they fail. The Board is also proposing a rule to impose similar requirements at the holding company level, prohibiting such institutions from engaging in certain activities, and changing its Total Loss Absorbing Capacity rule applicable to certain Global Systemically Important Banks (located at 12 CFR 252.60(b)(2) and .160(b)(2)).

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Submitted By
01. Breckinridge Capital Advisors, Peter B. Coffin
02. MEW Consul, Manfred E. Will
03. Bank Policy Institute and 4 other associations
04. Breckinridge Capital Advisors, Peter B. Coffin
05. James A. Marino
06. The Credit Roundtable
07. Independent Community Bankers of America, James Kendrick
08. Zions Bancorporation, Harris H. Simmons
09. SIFMA and SIFMA Asset Management Group
10. Fifth Third Bancorp
11. Better Markets, Inc
12. Discover Financial Services
13. Charles Schwab, Peter J. Morgan, III
14. Ally Financial Inc. and 3 other Organizations
15. Financial Services Forum
16. Institute of International Bankers
17. Ally Financial Inc. and 8 other organizations
18. Americans for Financial Reform Education Fund
19. U.S. Bank
20. Bank Policy Institute
21. Regions Financial Corporation
22. Conference of State Bank Supervisors
23. Anat R. Admati
24. Americans for Tax Reform
25. Public Citizen
Meeting Memoranda
01. Meeting Between Staff of the Federal Deposit Insurance Corporation, Federal Reserve Board, Office of the Comptroller of the Currency, and Representatives from RBC Capital Markets LLC
02. Meeting Between Staff of the Federal Deposit Insurance Corporation, Federal Reserve Board, Office of the Comptroller of the Currency, and a Representative from RBC Capital Markets LLC
03. Meeting Between the Chairman and Supervision Leadership of the Federal Deposit Insurance Corporation and the Conference of State Bank Supervisors Executive Committee