CIBC Investor Presentation
Canadian Bail-in Regime Update
On April 18, 2018, Department of Finance published the bail-in regulations, and OSFI finalized the guidelines on Total Loss Absorbing
Capacity (TLAC) and TLAC holdings.
Department of Finance's bank recapitalization (bail-in) conversion regulations
Provide statutory powers to CDIC (through Governor in Council) to enact the bail-in regime including the ability to convert specified eligible shares and liabilities of D-SIBS
into common shares in the event such bank becomes non-viable
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Bail-in eligible liabilities include tradable (with CUSIP/ISIN), unsecured debt with original maturity of over 400 days
Excluded liabilities are covered bonds, consumer deposits, secured liabilities, derivatives, and structured notes¹
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Effective on September 23, 2018
OSFI's TLAC Guideline
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TLAC liabilities must be directly issued by the D-SIB, satisfy all of the requirements set out in the bail-in regulations, and have residual maturity greater than 365 days
Minimum requirements:
TLAC ratio = TLAC measure / RWA > 21.5%
TLAC leverage ratio = TLAC measure / Leverage exposure
6.75%
TLAC supervisory target ratio set at 22.50% RWA²
Effective Fiscal 2022. Public disclosure began in Q1 2019
OSFI's TLAC Holdings
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Our investment in other G-SIBS and other Canadian D-SIB's TLAC instruments are to be deducted from our own tier 2 capital if our aggregate holding, together with
investments in capital instruments of other Fls, exceed 10% of our own CET1 capital
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Implementation started in Q1 2019
1 As referenced in the Bank Recapitalization (Bail-in) Regulations: http://laws-lois.justice.gc.ca/eng/regulations/SOR-2018-57/FullText.html
2 Decreased to 22.50% on March 13, 2020 upon decrease of Domestic Stability Buffer to 1.00% (buffer will not increase for at least 18 months)
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