Regulatory Alerts2023-09-19 | 2023-19265Long-Term Debt Requirements for Large Bank Holding Companies, Certain Intermediate Holding Companies of Foreign Banking Organizations, and Large Insured Depository Institutions
The OCC, Federal Reserve, and FDIC propose a joint rule requiring large bank holding companies, certain foreign banking intermediate holding companies, and large insured depository institutions to issue and maintain a minimum amount of long-term debt. The mandate targets non-global systemically important banking organizations with at least $100 billion in consolidated assets, requiring them to hold either externally or internally issued loss-absorbing debt instruments. By strengthening funding stability and resolution flexibility, the proposal reduces potential costs to the Deposit Insurance Fund and mitigates systemic contagion risks from uninsured deposit runs.
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