Final TLAC Rules and Structured Products -
On December 15, 2016, the Board of Governors of the Federal Reserve System (the “Federal Reserve”) issued its final rules regarding long-term debt and total loss absorbing capacity (“TLAC”) requirements for global systemically important banks (“G-SIBs”) in the United States. In this article, we discuss the effect of these rules on the U.S. structured products market.
Generally speaking, the final rules are consistent with the 2015 proposed rules, with some important modifications for the intermediate holding companies (“IHCs”) of foreign banking organizations (“FBOs”) that are G-SIBs and are subject to an IHC requirement.
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