TCH filed comment letters responding to two recent consultations issued by the Financial Stability Board (FSB) on resolution-related topics: (i) guidance on continuity of access to financial market infrastructures (FMIs) for a firm in resolution; and (ii) guiding principles on internal TLAC. The FMI related consultation seeks to address the risk that a bank in resolution might be unable to maintain access to the clearing, payment, settlement and custody services provided by FMIs that are necessary to continue the provision of a bank’s critical functions in resolution, and the TCH comment letter was generally supportive of the FSB’s efforts with recommendations for minor adjustments. The internal TLAC consultation proposes a set of guiding principles to support the implementation of the internal TLAC requirement, and the TCH comment letter offered a set of constructive suggestions for how the guidance could be amended to support and facilitate, and not undermine, a ‘single point of entry’ resolution strategy.
Bank Activities and Structure
The FDIC’s Proposed Increase in Deposit Insurance Assessments May Be Based On Incorrect Projections
The FDIC’s Proposed Increase in Deposit Insurance Assessments May Be Based On Incorrect Projections
Bank Liquidity
Imposition of SPOE and TLAC Requirements on Large Regional Banks is Unnecessary to Promote Financial Stability
Imposition of SPOE and TLAC Requirements on Large Regional Banks is Unnecessary to Promote Financial Stability
Bank Liquidity
Applying Global Bank Resolution Rules to Regional Banks Would Undermine Bipartisan Tailoring Efforts, Increase Costs for Borrowers and Produce No Tangible Public Benefit
Applying Global Bank Resolution Rules to Regional Banks Would Undermine Bipartisan Tailoring Efforts, Increase Costs for Borrowers and Produce No Tangible Public Benefit
Resolution & Recovery Planning
Any Major Revamp of Bank Resolution Plan Requirements Should be Done Only Through Rulemaking
Any Major Revamp of Bank Resolution Plan Requirements Should be Done Only Through Rulemaking
Resolution & Recovery Planning
Putting “Too Big to Fail” to Rest: Evidence from Market Behavior in the COVID-19 Pandemic
Putting “Too Big to Fail” to Rest: Evidence from Market Behavior in the COVID-19 Pandemic
Digital Assets
BPI Comments on Treasury Department Review of Digital Assets in Response to Executive Order
BPI Comments on Treasury Department Review of Digital Assets in Response to Executive Order
Community Reinvestment Act
BPI Comments on Federal Banking Agencies’ Community Reinvestment Act Proposal
BPI Comments on Federal Banking Agencies’ Community Reinvestment Act Proposal
