A Game-Changing Regulatory Shift: OCC & FDIC Rescind Leveraged Lending Guidance

The news on December 5, 2025, that the Federal Deposit Insurance Corporation (FDIC) and Office of the Comptroller of the Currency formally withdrew the 2013 Interagency Leveraged Lending Guidance is the most consequential development for bank balance sheets and the broadly syndicated loan (“BSL”) market in years.

What just happened? The 2013 Guidance was effectively an uncodified rule that was deemed overly restrictive and pushed trillions of dollars in leveraged lending outside the regulatory perimeter and into the hands of nonbanks such as private credit managers. Its withdrawal provides the clarity the banking industry has long awaited. The FDIC and OCC now direct banks to apply general principles for safe and sound lending, instead of the prior rigid, and often ambiguous guidelines.

The Caird Investment Partners, LLC Opportunity: For banks and regulated financial institutions, this is a compelling strategy for responsible, active participation in the BSL asset class. While our offering was carefully created to match this guidance, this rescission provides clarity on the regulators’ stances regarding broadly syndicated loans. Critically, Caird will maintain the rigorous risk discipline of the former guidance, continuing to provide all necessary support and deliverables that exceed those prior standards.

At Caird, our expertise is built precisely on the intersection of liquid capital markets and regulated banking. Our proprietary processes were originally designed for the rigid guidance, but they now seek to offer banks a highly regulatory-friendly method to manage syndicated loans that aligns with the new, safe-and-sound standards emphasized by the FDIC and OCC.
The door is open for banks to responsibly add liquid assets, grow C&I loans, diversify away from CRE, and potentially increase ROE by strategically allocating to broadly syndicated loans.

Banks must act decisively to define new risk parameters; those that execute an optimized BSL strategy now may secure the strongest position for future outperformance.