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The OCC, the Federal Reserve Board and the FDIC proposed long-term debt requirements for large banking entities, holding companies, foreign banking organizations and large insured depository institutions to facilitate resolvability in the event of failure and to reduce the risk of contagion within the financial system.

The Board of Governors of the Federal Reserve System ("FRB") Associate Director of Banking Supervision and Regulation Thomas Sullivan stated that the FRB is constructing a domestic regulatory capital framework for its supervised insurance holding companies that is "well tailored to the business of insurance." The development of the framework stems from Congress's enactment of the Insurance Capital Standards Clarification Act of 2014 (S. 2270). This Act amended the Dodd-Frank Act provision that previously had required the minimum capital standards to be applied to any insurance holding company