Following the recent failures of Silicon Valley Bank and Signature Bank, U.S. bank regulators are being encouraged to require that regional bank holding companies (BHCs) issue added debt, which is one component of total loss-absorbing capacity (TLAC), to facilitate the resolution of a bank when it fails. In the original vision for TLAC, if a bank and its parent BHC were to fail, the Federal Deposit Insurance Corporation (FDIC) would take the BHC into receivership and reconstitute it as a new company with its bank subsidiaries remaining in place and operating normally. To facilitate this process, the BHC would be required to have long-term debt available to absorb losses after its equity is extinguished and to recapitalize the subsidiaries sufficiently to continue under a new holding company. The presumption is that such a transition could be accomplished without financial panic or significant government funding and could reduce losses to the FDIC’s deposit insurance fund.