Moving cautiously to assess the extent to which large banks are no longer too big to fail (TBTF), the FSB has gone beyond a request for comment to a somewhat more specific solution that may lead to policy actions not yet spelled out for public comment in this report.  The FSB does, however, lay out what it describes as “gaps” in the anti-TBTF regime for consideration by its member agencies, with the Basel Committee principally targeted here since the report addresses only banks.  Looking only at the period before the pandemic and only at global systemically-important banks (GSIBs) and those designated as domestic SIBs, the FSB preliminarily concludes that many nations – and perhaps most notably the U.S. – have indeed quelled TBTF banking.

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