On March 30, the Fed, OCC and FDIC issued Proposed Guidance on Leveraged Lending. On June 8, 2012, the LSTA, together with the American Bankers Association (ABA), responded with comments to such guidelines. The comments suggested that more modest changes to the current leveraged finance guidance would allow banks to continue to safely manage the risks of leveraged finance without imposing undue burdens. Generally, the comments noted the costs of implementing the guidelines in comparison to the potential benefits and emphasized that the guidelines are only recommendations that need to remain flexible enough for implementation by a variety of lending institutions across the broad spectrum of leveraged lending transactions. Proposed Guidance. LSTA and ABA Comments.