In the fall of 2017, the Board of Governors of the Federal
Reserve System, the Federal Deposit Insurance Corporation and the
Office of the Comptroller of the Currency promulgated new rules as
part of their ongoing efforts to address the
"too-big-to-fail" problem.1
The new rules require U.S. global systemically important banking
organizations, or GSIBs, as designated by the Basel Committee on
Banking Supervision and the Financial Stability Board, the
subsidiaries of U.S. GSIBs (including state member and nonmember
banks and state savings associations and most of their
subsidiaries), national banks or federal savings associations that
have more than $700 billion in assets, and the U.S. subsidiaries,
branches or agencies of non-U.S. GSIBs (collectively, covered
entities)2 to amend certain types of financial
contracts, including securities contracts, swaps and other types of
derivatives, repurchase and reverse repurchase agreements and
securities lending arrangements