TLAC Timeline

A Cautionary TLAC Slap

Karen Shaw Petrou's memorandum to the Federal Financial Analytics clients on a cautionary TLAC slap.
TO: Federal Financial Analytics Clients

FROM: Karen Shaw Petrou

DATE: November 20, 2015

The House yesterday voted on strictly-partisan lines in favor of sweeping FRB-reform legislation that in a largely-unnoticed provision subjects the central bank to extensive cost-benefit analysis (CBA) standards. These are meant mostly to throw the Board rulemakings down so deep an analytical hole that they never come out. Chair Yellen thus protested the CBA provisions, but the FRB could bolster its justifiable case by making it far . . .

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