Status: Draft -- Not PublishedWill be live at 02/26/2016 00:00
IIF/GFMA Response to the BCBS's Consultation Paper on TLAC Holdings
Friday, February 26, 2016
The Associations agree with the basic goals of having TLAC available to assure orderly resolution of G-SIBs without recourse to public funds, and the concomitant goal of avoiding contagion. Nonetheless, the Associations argue that reconsideration of the proposal is necessary to achieve these goals in the most proportionate and effective manner, taking due account of the need to sustain a substantial market for TLAC and capital instruments in financial institutions generally. Supporting healthy markets for the very large amounts of TLAC that will be required will be important to the success of an effective bank resolution as intended by the FSB. Reconsideration needs to include differences in the effects on and differing needs of G-SIBs and non-G-SIBs as they would be affected by the TLAC holdings rules. The proposed Tier 2 deduction approach is not optimal or necessary and would needlessly burden banks' ability to participate in healthy markets for TLAC. The Associations outline ways to meet the goals of the Committee expressed in the consultative document while better supporting
vital markets for TLAC.