IIF Authors

Status: Will be live at 08/10/2016 00:00

IIF GFMA Follow-up Comments on TLAC Holdings

Wednesday, August 10, 2016

The proposed limitations on cross-holdings among banks of TLAC for market-making or investment purposes are likely to have a significant impact on the depth and liquidity of the market for the very large amounts of TLAC that have to be issued. The supplemental letter underscores in particular the importance of a sufficient allowance for cross-holdings of TLAC, suggesting at least 10% of CET1 (in addition to the existing allowance for bank equity and other instruments).'