Reflecting continuing doubts that post-crisis reforms are achieving their desired goals a decade after a pivotal Group of Twenty summit in 2009, the FSB is assessing the extent to which too-big-to-fail (TBTF) reforms have indeed quelled taxpayer risk and moral hazard and if changes to date have had unintended consequences. The FSB plans to look principally at total loss-absorbing capacity (TLAC) requirements, enhanced supervision, and resolvability – key planks of its own post-crisis work. However, even as it does so, it plans to complete pending actions in all of these areas, suggesting that the timeline for any structural change to the rules addressing TBTF due to this inquiry is going to take years, years in which many features of global finance may change so materially as to render moot many of the questions posed here. That said, this evaluation provides a global forum to consider the extent to which TBTF has been addressed, the merits of different national approaches, and ways to enhance the continuing goal of ending taxpayer bail-outs of large financial institutions.
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