Attached, please find a letter to the Feds from our friends at Sandler O’Neill Partners, L.P. commenting on Total Loss-Absorbing Capacity, Long-Term Debt, and Clean Holding Company Requirements for Systemically Important U.S. Bank Holding Companies and Intermediate Holding Companies of Systemically Important Foreign Banking Organizations; Regulatory Capital Deduction for Investment in Certain Unsecured Debt of Systemically Important Bank Holding Companies; Proposed Rule.
The comment letter was provided by Thomas W. Killian, Principal at Sandler O’Neil who can be reached at tkillian@sandleroneill.com or 212-466-7709.