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Commentary by Steven Lofchie

In a report based on an internal review of its supervision over First Republic Bank, the FDIC concluded that "meaningful action to mitigate interest rate risk and address funding concentrations would have made First Republic more resilient and less vulnerable to the March 2023 contagion event."

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.