FSB Publishes Responses to Consultation on Evaluation of TBTF Reforms

The evaluation, which is being conducted by a working group chaired by Claudia Buch (Vice-President of Deutsche Bundesbank), will assess whether the implemented reforms are reducing the systemic and moral hazard risks associated with the systemically important banks. It will also examine the broader effects of the reforms to address too-big-to-fail (for systemically important banks) on the overall functioning of the financial system. FSB had invited feedback—from banks, other financial institutions, academics, think tanks, industry, and consumer associations—on the following issues:

• To what extent are too-big-to-fail reforms achieving their objectives, as described in the terms of reference? Are they reducing the systemic and moral hazard risks associated with systemically important banks?
• Which types of too-big-to-fail policies (for example: higher loss absorbency, total loss-absorbing capacity, more intensive supervision, resolution and resolvability) have had an impact on systemically important banks and how? 
• Is there any evidence that the effects of these reforms differ by type of bank (for example: global vs. domestic systemically important banks)?
• What have been the broader effects of these reforms on financial system resilience and structure, the functioning of financial markets, the global financial integration, or the cost and availability of financing?
• Have there been any material unintended consequences from the implementation of these reforms to date?
• Any other issues related to the effects of too-big-to-fail reforms that have not been covered in the questions above.

Related Links

• Responses to Consultation
• Press Release on Consultation
• Summary Terms of Reference (PDF)

Keywords: International, Banking, Too Big to Fail, Systemic Risk, TLAC, Resolution, Crisis Management, Responses to Consultation, FSB