In May 2017, the European Central Bank published its final Guidance on Leveraged Transactions (the "ECB Guidance")1. The ECB Guidance will come into effect six months after publication and will apply to all "significant credit institutions" supervised by the ECB. As we discussed in our previous note2, when drafting its guidance the ECB took into account comments from market participants, many of which focused on aligning the ECB Guidance with the Interagency Guidance on Leveraged Lending (the "US Guidance")3 promulgated by the several departments of the United States government in March 2013. In this note, we give a more specific comparison of significant points-to-note in the ECB Guidance and the US Guidance.
Footnotes
1 The European Central Bank's Final Guidance on Leveraged Transactions (May 16, 2017), to be read in conjunction with the ECB's Feedback Statement.
2 ECB Publishes Final Guidance on Leveraged Transactions - what this means for banks (Shearman & Sterling, May 22, 2017).
3 Interagency Guidance on Leveraged Lending, 78 Fed. Reg. 17,766 (March 22, 2013).
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