TLAC: what you should know
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TLAC: what you should know

We explain the FSB's total loss-absorbing capacity requirements for global systemically important banks (G-Sibs).

The Financial Stability Board (FSB) issued the final minimum total loss-absorbing capacity (TLAC) standard for 30 banks identified as global systemically important banks (G-Sibs) that the Basel Committee on Banking Supervision (BCBS) deems at risk from being too big to fail on 9 November 2015.

The TLAC requirements aim to bolster G-Sibs' capital and leverage ratios, ensuring these banks are equipped to continue critical functions without threatening financial market stability or requiring further taxpayer support.

A comprehensive quantitative impact study (QIS) was completed by the FSB in collaboration with the BCBS to calibrate the optimal Pillar 1 element of the TLAC requirement for all G-Sibs. The FSB proposed a minimum total loss-absorbing capacity (TLAC) requirement for G-Sibs in November 2014, in consultation with the BCBS.Basel III rules require banks to meet a minimum total capital ratio of 10.5% by 2019 – though in some jurisdictions the minimum ratio is far higher. The proposed minimum TLAC requirements for G-Sibs unveiled at the G20 Brisbane summit in November 2014 was 16% to 20% of a group's consolidated risk-weighted assets. This proposal was under consultation until February 2, 2015, when the requirement was finalized.

Qualifying instruments

The TLAC should consist of instruments that can be written down or converted into equity in case of resolution: capital instruments (CET1, AdT1 and T2), together with long-term unsecured debt – subordinated and senior debt. Debt must be unsecured; have a minimum residual maturity of more than one year; arise through a contract; and be subordinated to liabilities that are explicitly excluded from TLAC.

The minimum TLAC requirement is in addition to minimum regulatory capital requirements, but qualifying capital may count towards both requirements, subject to conditions.

TLAC calibration

From 1 January 2019, the minimum TLAC requirement for G-Sibs is at least 16% of the resolution group’s risk-weighted assets (RWA's), increasing to at least 18% from 1 January 2022. Emerging market G-Sibs must meet the 16% RWA and 6% LRE Minimum TLAC requirement no later than 1 January 2025, and the 18% RWA and 6.75% LRE minimum TLAC requirement before 1 January 2028. The period for emerging market G-Sibs conformance accelerates if, in the five years following publication of the term sheet, aggregated corporate debt issuance exceeds 55% of the economy's GDP.

Bank manoeuvres

Banks still have much work to do filling out their TLAC ratios at the lowest possible cost.

New Basel regulations disqualify old-style amortizing tier-2 bonds with less than five years remaining to maturity to count in the TLAC computation. In February and early March 2015, a slew of European banks issued 10-year bullet maturity Basel III-compliant, tier-2 (B3T2) subordinated bond deals, as they sought to grow a new market for these lower cost TLAC-eligible instruments. Investor yield-hunger drove strong demand for bonds offering coupons around 2.625%.

  • Crédit Agricole drew €16.5 billion of orders for its €3 billion dual-tranche T2 bond.

  • BNP Paribas attracted €5.5 billion of demand for its €1.5 billion offering at 170 basis points over mid-swaps.

  • Deutsche Bank took €4.4 billion of orders for its €1.25 billion deal priced at 210bp over.

  • Société Générale drew €3.8 billion of orders for its €1.25 billion transaction at 190bp over.

Under the proposed rules, TLAC eligible debt must qualify as long-term debt (LTD) – no debt instruments with residual maturity of less than one year can count towards these ratios. Eligible debt with remaining maturities between one to two years still qualify, but at a 50% haircut. US banks have begun issuing senior debt with call options one year before maturity, with plans to redeem the debt before it stops counting towards their TLAC requirement, allowing them to save on interest payments for debt with no regulatory benefit.

JPMorgan issued the first deal to use a call feature to address TLAC rules in August 2016; the $2.5 billion of five-year bonds that can be called in their fourth year brought in $5.5 billion of orders.

In the four months following JPMorgan's initial deal, more than $20 billion equivalent of callable senior debt was printed. Reuters reports: "Wells Fargo, Bank of New York Mellon and State Street are the only banks subject to TLAC that have not yet tapped the callable structure." Issuer calls are subject to regulatory approval if calling the issue would result in breach of TLAC.

TLAC is formally implemented in 2019. Once established, non-compliance could impede a bank’s ability to make discretionary distributions such as dividend payments or additional tier-1 coupons, as TLAC is part of the Pillar 1 Basel requirements.


Recent Euromoney coverage

EC calls for May deadline as stalemate over bank creditor hierarchy legislation sets in

March 2017

European Parliament drags heels over fast-tracking rules; Nykredit flips out in €500 million deal.

Asymmetric finalization of capital rules creates headache for Europe’s banks

February 2017

head split-600

G-Sibs face conflicting TLAC and MREL requirements; deduction rules could favour European bank investors.

French banks pile up to issue TLAC-compliant senior debt

January 2017

€9.5 billion issued after Sapin 2 law passed; EC chooses French instrument for harmonized solution.

Spirit of TLAC broken as regulators mark their ground

December 2016

A last-minute proposal by the European Commission risks throwing global bank capitalization rules into further flux.

Basel IV capital demands spell trouble for AT1

October 2016

With TLAC and minimum requirement for own funds and eligible liabilities (MREL) due to be in place by 2019, the focus on both the quantum and form of bank capital is intense. JPMorgan repo retreat shows cost of rule changes

September 2016

The leverage ratio requirement makes the relative cost of capital too high for low-margin activities such as repos because all assets are treated the same. The systemically important bank buffer, which US regulators use for total loss-absorbing capacity (TLAC) purposes, is another factor because it means big banks need to hold more debt as well as more capital.

Bank capital: Deutsche offers sub-debt solace

June 2016

Deal shows appetite after February sell-off; bank’s tier-2 issuance could herald TLAC surge.

Basel’s IRB attack ‘a capital game-changer’

May 2016

The fear is that the clampdown on the IRB and risk-weight changes to the standardized approach together represent wholesale changes to the bank-capital framework, given the interconnected nature of rulemakings, including on the total loss-absorbing capacity standards.

Regulatory crisis rocks bail-in

February 2016

Subordinated debt meltdown raises capital questions; investors and issuers ‘don’t know’ how bail-in works.

Bank capital: Market looks for tier-2 surge

January 2016

Flight to AT1 from high yield expected; tier 2 needed to mitigate ALAC impact.

The eternal struggle of the bank treasurer

October 2015


Having spent the years since 2008 focusing on building up their capital buffers, banks are now faced with the dual headache of leverage rules and looming total loss-absorbing capacity (TLAC) requirements, never mind further potential Basel IV changes in treatment to risk-weighted assets.

Bank capital: Banks brace for TLAC terms, clarity still needed

October 2015

Tier-3 debt faces contractual hurdles; FSB accedes on structure disparities.

Bank capital: Germany solves TLAC eligibility ‘at stroke of a pen’

June 2015

Rule to bail in all bank senior debt; initial Schuldscheine exemption reversed.

Banks spread the search for tier-2 buyers

March 2015 

Last month a slew of European banks issued 10-year bullet maturity Basel III-compliant, tier-2 (B3T2) subordinated bond deals, as they sought to grow a new market for these lower cost total loss-absorbing capacity (TLAC)-eligible instruments. 

Turkey: New rules prompt Vakifbank tier-2 move

February 2015

Basel III law opens up funding; investors bring $1 billion book.

TLAC: Fears for tiers

January 2015

As 2015 dawns, senior bankers are still poring over the implications of the Financial Stability Board’s proposals to boost their total loss absorbing capacity (TLAC) to ensure that beyond common equity, Additional Tier 1 capital and Tier 2 subordinated debt, banks still have enough liabilities on which losses can be imposed in the event of a failure so that taxpayers never again have to bail them out.

AT1 supply surges, while TLAC raises concerns

January 2015

“Some investors will be very nervous about what TLAC means for future supply,” says one banker. “There may be friction between what issuers want to issue and what investors are prepared to buy.” That nervousness isn’t helped by the lack of clarity around the shape and size of this future market.”

EU-US tensions remain over leverage ratio
January 2015

US officials are waging a war to promote the leverage ratio as a binding constraint on banks’ capital frameworks, further imperilling strategic planning for cross-border lenders.

Thomas Hoenig interview: Battle against too-big-to-fail fragments banking

January 2015

Haunted by the global crisis, policymakers from the US to the UK are erecting national barriers and waging a war against too-big-to-fail banking. Vice-chairman of the Federal Deposit Insurance Corp Thomas Hoenig defends the drive toward balkanization.

Regulation puts global banking in peril

December 2014

Collateral damage of the focus on too-big-to-fail, capital rules and bankruptcy resolution risk rolling back financial globalization. 



TLAC and bank M&A: Europe needs consolidation, not recapitalization

December 2014

Debt service costs will hit profits; regulators see M&A as the answer.


Bundesbank’s Dombret says trust restored in European banking system

November 17, 2014

In an interview with Euromoney, Bundesbank board member Andreas Dombret sounds an upbeat note on the rigour of the ECB’s asset-quality review (AQR) and the eurozone’s resolution arrangements, but issues a sharp warning over banks’ risk-free treatment of sovereign debt. 


Stress tests and TLAC will transform bank funding markets

October 24, 2014

Bankers are looking past Sunday's publication of the stress-test results and the TLAC requirements that will follow to a substantial change in how banks fund in the capital markets and maybe even new forms of senior debt. 

Market braces for FSB's 'scary' TLAC number

September 29, 2014

The November G20 meeting could see the capital requirements of systemically important banks doubled. 

Investors fill banks' capital begging bowls

Euromoney April 2014

Overwhelming demand for a string of bank AT1 deals shows the extent of investors’ desperation for yield as much as their faith in the restored health of the banking sector. As more new investors accept these deals, hopes grow that a €150 billion AT1 market might emerge quickly now. But terms have tightened far and fast and AT1 can be volatile. 

Resolution requirements set to boost G-Sifi holdco debt buffer levels February 2013

Citi, BAML and JPMorgan might need to issue subordinated debt to meet OLA requirement.


From the Euromoney archive

TBTF book

"Too big to fail – The hazards of bank bailouts was written in 2004 – when the authors decided that the too-big-to-fail (TBTF) problem was serious and getting worse.... The authors argue that one of the ways to manage TBTF is to put creditors at risk of real loss. They also suggest policymakers should attempt to institute reforms that prevent the failure of one bank spilling over to another and that provide regulators with greater certainty of how to deal with a bank defaulting."

Maestro, my ass! How we got into this mess: Breaking the Maestro’s baton, Euromoney August 2009. 

"One of the natural consequences of government support for banks that are deemed too big to fail is that those banks will have to be more tightly regulated."

Banks begin great financial retrenchment, Euromoney June 2009.

"If you gave your assets to Lehman as collateral and they lent those out, then more than one person has a claim on those assets. Everyone passes around the security, then the music stops, there is one chair to sit on and too many people who want to sit on it. I cannot see how PwC is going to work that out. And I think the outcome will be that Lehman really was too big to fail."

-Prime brokerage: The day the music stopped, Euromoney, November 2008. 


"Absolutely no bank is too big to fail," says governor Laurence H Meyer of the Federal Reserve Board, "if the measure is whether shareholders take a loss and management gets replaced."

-US bank regulation - Winners and losers of new finance law, Euromoney December 1999. 


"...innovation in the next century concerns liquidity risk measurement... Most banking supervisors require a portion of assets to be in instruments which can be easily liquidated... If a firm has been carrying those assets linked to short-term funding at liquidation values, the initial phase of a crisis can be weathered. However, if the loss of confidence persists, then it is up to the central bank to provide what amounts to re-insurance. Regulatory capital can be thought of as the deductible on that re-insurance coverage. From this perspective, any financial firm whose failure would generate systemic risk (too big to fail) must carry proper capital for all of its activities."

-Euromoney 30th anniversary: The future of risk, Euromoney June 1999.


"A bank which regulators regard as too important or too big to fail enjoys a free put option on its home government and taxpayers. Regulators are right to demand something in return for that option, such as a certain level of regulatory capital or minimum reserves."

-The rise and rise of the risk manager. Euromoney February 1998.


External resources: Speeches, consultation papers from the FSB, BIS, BOE, EBA

Final standard on TLAC holdings published by the Basel Committee

12 October 2016

TLAC Principles and Term Sheet

9 November 2015

Financial Stability Board 

FSB issues final Total Loss-Absorbing Capacity standard for global systemically important banks

9 November 2015

Financial Stability Board 

Summary of Findings from the TLAC Impact Assessment Studies

9 November 2015

Financial Stability Board 

Why we need a leverage ratio, and how bank boards might take charge

20 November 2014

Speech given by  Martin Taylor, External Member of the Financial Policy Committee, Bank of England. Oliver Wyman Institute annual conference, London.

18 November 2014Mark Carney, Chair of the FSB, answered questions from media persons in Basel on 10 November 2014 on too big to fail, total loss absorbing capital and ending implicit public subsidies for banks.

The future of financial reform

17 November 2014

Speech given by Mark Carney, Governor of the Bank of England, Chair of the Financial Stability Board. 2014 Monetary Authority of Singapore Lecture.

Towards full implementation of the FSB Key Attributes of Effective Resolution Regimes for Financial Institutions

12 November 2014

Report to the G20 on progress in reform of resolution regimes and resolution planning for global systemically important financial institutions (G-SIFIs).

FSB consults on proposal for a common international standard on Total Loss-Absorbing Capacity (TLAC) for global systemic banks

10 November 2014

The Financial Stability Board (FSB) has today issued for public consultation policy proposals consisting of a set of principles and a detailed term sheet on the adequacy of loss-absorbing and recapitalisation capacity of global systemically important banks (G-Sibs). Under consultation until 2 February 2015. During the consultation period, the FSB will collaborate with the Basel Committee on Banking Supervision to carry out a Quantitative Impact study to assess optimal Pillar 1 minimum TLAC requirement. 

The Bank of England’s Sterling Monetary Framework

Updated November 2014

How fair and effective are the fixed income, foreign exchange and commodities markets?

October 2014

Fair and Effective Markets Review consultation document

Enhancing financial stability by improving culture in the financial services industry

October 20, 2014

William C. Dudley, President and Chief Executive Officer.Remarks at the Workshop on Reforming Culture and Behavior in the Financial Services Industry, Federal Reserve Bank of New York, New York City

EBA Discussion Paper on simple standard and transparent securitisations

14 October 2014

Response to the Commission’s call for advice of December 2013 related to the merits of, and the potential ways of, promoting a safe and stable securitisation market

Financial Stability Board Enhanced Disclosure Task Force 2014 Progress Report

5 September 2014

The Financial Policy Committee’s review of the leverage ratio: a consultation paper

July 2014

Bank of England

The case for a better functioning securitisation market in the European Union: a discussion paper

May 2014

European Central Bank and Bank of England

Global systemically important banks: Assessment methodology and the additional loss absorbency requirement

Updated April 2014

Basel Commitee on Banking Supervision

Supervisory Intensity and Effectiveness

FSB Progress Report on Enhanced Supervision 

7 April 2014

Cometh the UK leverage ratio, cometh the deleveraging – in pictures 

26 November 2013

Why the UK - and European - bank-deleveraging cycle has much further to go, following George Osborne's call for the Bank of England to review leverage ratios.

Progress and Next Steps Towards Ending “Too-Big-To-Fail” (TBTF)

2 September 2013

Report of the Financial Stability Board to the G-20, FSB, 

Building resilient financial institutions and ending “too-big-to-fail”

September 2013

G20 leaders' declaration, Russia G20

Macroeconomic impact assessment of OTC derivatives regulatory reforms

August 2013

Macroeconomic Assessment Group on Derivatives established by the OTC Derivatives Coordination Group

Building a resilient financial system: Keynote speech by Jaime Caruana General Manager, Bank for International Settlements 

7 February 2012

ADB Financial Sector Forum on “Enhancing financial stability – issues and challenges”, Manilla.

Basel Committee on Banking Supervision: Results of the comprehensive quantitative impact study

December 2010

Reducing the Moral Hazard Posed by Systemically Important Financial Institutions

20 October 2010

FSB recommendations and time lines

Building a more resilient financial system

June 2009

Bank of England financial stability report 

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