Can a holding company that has no liabilities as of September 30, 2008 issue senior unsecured debt guaranteed by the FDIC?
In order to issue guaranteed debt the holding company must seek to have some amount of debt covered under the Temporary Liquidity Guarantee Program. The FDIC, after consultation with the appropriate federal regulator, will decide on a case-by-case basis whether such a request will be granted and what that entity’s debt limit will be. Holding companies are not eligible to use the two percent of liabilities option.
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