Reflecting a continuing obstacle to ending TBTF banks, the FSB has finalized guidance to stipulate how nations should ensure that GSIBs can fail without resorting to taxpayers to the greatest extent possible.  Although a step towards global action on regimes akin to the U.S. OLA for GSIBs and other SIFIs, the FSB approach continues to accept that public funding may be required.  This, it hopes, would be only on a temporary basis, but the FSB implicitly recognizes not only cross-border problems to orderly resolution, but also nations where banks remain de facto arms of the national government and thus will not be allowed to fail.  Much in these guiding principles is broadly phrased and thus gives national authorities the considerable discretion many would regardless use in a GSIB resolution due to binding statutory requirements and/or national-policy imperatives.  It may be due to these considerations that the FSB concluded when it issued this guidance and other resolution protocols that GSIBs remain TBTF.

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