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Fed fractures post-SVB consensus on emergency liquidity

New supervisory principles support FHLB funding over discount window preparedness

It was as close to a regulatory consensus as seems possible these days.

After the collapse of Silicon Valley Bank in 2023, regulators generally agreed that US banks had become too dependent on the Federal Home Loan Bank (FHLB) system for funding, and that they needed to be better prepared to use the Federal Reserve’s discount window in an emergency.

At the end of October 2025, the Fed issued a new statement of supervisory operating principles explicitly setting out the changes Michelle Bowman

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