- Fed officials proposed that large banks limit their exposure to a single counterparty to 15% or 25% of their Tier 1 capital under Dodd-Frank.
- The Fed estimates that banks collectively will need to reduce their current counterparty exposure by $100B to get below the credit limits.
- However, the Fed made some concessions to banks complaints of its 2011 proposal; the credit limits exempt exposures to certain clearinghouses and high quality sovereign debt.