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The US federal banking regulators have jointly proposed long-term debt (“LTD”) requirements for certain midsize and larger US banking organizations. The LTD proposal would require many regional and larger banking organizations to issue approximately $70 billion of new LTD over the three-year implementation period. Additionally, affected organizations would need to restructure their top-tier holding company activities to comply with the clean holding company requirements, and conform funding arrangements with most subsidiary depository institutions to implement internal LTD measures.