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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.

Commentary by Steven Lofchie

In response to an Advance Noticed of Proposed Rulemaking that would add "an extra layer of loss-absorbing capacity" in resolving certain large banking organizations, SIFMA said that it is both unnecessary and inappropriate to extend the enhanced resolution requirements to non global systemically important banking organizations whose primary operations are as retail broker-dealers.