US banks and US BHCs are awaiting word from the FED to clarify rules associated with TLAC, or total loss absorbing capital. Depending upon the outcome of these rules, up to $500 billion of new capital theoretically may be required, according to research firm CreditSights (the FED itself believes the swing factor is smaller, only $120 billion, according to IFR). I reckon some grandfathering may be in the cards here... The rub is that senior debt issuance via US BHCs has been historically assumed to qualify for the FSB rules on subordinated debt and thus loss-absorbing.
However a recent paper from the Federal Reserve (see http://www.federalreserve.gov/newsevents/press/bcreg/20151030a.htm) may change these assumptions, leading to the need to raise more capital. We will all have to wait until February 2016 when the FED comment period expires to find out the outcome of this issue, further evidence of the game of Banking Twister where banks must meet multiple, often contradictory expectations while also managing through high levels of regulatory uncertainty.
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