TCH Files Comment Letter on FDIC’s Single-Point-Of-Entry

In December 2013, the FDIC issued for comment a Notice providing further detail about its “single-point-of-entry” (SPOE) strategy for resolving a U.S. G-SIB under Title II. Under SPOE, losses would be imposed on the parent company’s equity and debt holders, and critical operating subsidiaries would be recapitalized using parent company resources and transferred to a bridge holding company, allowing systemically significant functions to continue uninterrupted. Today, TCH, in coordination with ABA, FSR, and GFMA, filed a letter with the FDIC supporting the SPOE strategy and recommending ways to strengthen the Notice.