Capital Markets & Funding Strategies
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.
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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
•
Bail-in eligible liabilities include tradable (with CUSIP/ISIN), unsecured debt with original maturity of over 400 days
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Excluded liabilities are covered bonds, consumer deposits, secured liabilities, derivatives, and structured notes 1
.
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:
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TLAC ratio = TLAC measure / RWA > 21.5%
.
TLAC leverage ratio = TLAC measure / Leverage exposure > 6.75%
•
TLAC supervisory target ratio set at 24.00% RWA 2
•
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
Implementation started in Q1 2019
CIBC
1 As referenced in the Bank Recapitalization (Bail-in) Regulations: http://laws-lois.justice.gc.ca/eng/regulations/SOR-2018-57/FullText.html
2 Increased to 24.00% on October 31, 2021 upon increase of Domestic Stability Buffer to 2.50% (the maximum) from 1.00%
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