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A little less than a year ago, the US financial system was rocked by its first major banking drama since 2008. While the crisis was eventually contained, and only three lenders ended up collapsing, the experience re-ignited an ongoing conversation about the way we rescue troubled lenders. Not only did the Federal Reserve launch a new liquidity program called the Bank Term Funding Program as part of its support to the banking system in 2023, but regulators are now talking about changing existing facilities, including the Federal Home Loan Banks (FHLBs) and the discount window. For instance, Michael Hsu of the Office of the Comptroller of the Currency has proposed that banks be required to tap the discount window and "pre-position" collateral at the facility, just in case they one day need it.
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