This A Closer Look focuses on one of the most significant proposed standards in the package of enhanced requirements for Systemically Important Financial Institutions (SIFIs) — single counterparty credit limits. The proposal introduces a two-tier limit, with a more stringent limit applied to the largest covered companies. A covered company's credit exposure to a counterparty would have to be calculated on a consolidated basis. The definition of a counterparty includes a company and all of its subsidiaries and governments (federal, state and foreign) calculated to include collectively agencies, instrumentalities and political subdivisions.
Depending on how the final rule reflects concerns of the industry and others, it is possible that the proposed limit could:
In this A Closer Look, we review and analyze the proposal, including the scope of application, applicable counterparties, limit level and the definition of capital and exposure.
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This A Closer Look follows our FS Regulatory Brief: The Federal Reserve’s proposal to implement enhanced prudential standards for large bank holding companies, issued in December, 2011, which reviewed at a high level the full menu of proposed SIFI standards.