Breaking Down the Proposed Rule to Bail In More Banks

Venable LLP

As part of the continuing financial regulatory reform efforts following the 2023 bank failures, the FDIC, the OCC, and the Federal Reserve issued a proposed rule that would generally require large banks and thrifts with total assets over $100 billion, as well as their holding companies, to issue and maintain outstanding a minimum amount of plain vanilla LTD that can be used to recapitalize these banking organizations in the event of their failure.

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DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

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Venable LLP

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