On December 15, 2016, the Board of Governors of the Federal Reserve System (the “Federal Reserve”) issued its final rules regarding total loss absorbing capacity (the “Final TLAC Rule”) requirements for global systemically important banks (“G-SIBs”) in the United States. The Final TLAC Rule is intended to “build on, and serve as a complement to, the regulatory capital requirements in Regulation Q.” The Federal Reserve originally proposed TLAC rules for G-SIBs in the United States (the “TLAC Proposal”) on October 30, 2015, through a notice of proposed rulemaking, which would have required the bank holding companies of U.S. G-SIBs (“covered BHCs”), as well as top-tier U.S. intermediate holding companies of foreign G-SIBs (“covered IHCs”), to maintain a minimum amount of loss-absorbing instruments, including capital and a minimum amount of unsecured long-term debt (“LTD”).

The following is an overview of the changes made in the Final TLAC Rule—we will provide a more detailed analysis in the coming days.