Following a series of ad hoc interventions throughout 2007 and early 2008, the collapse of Lehman Brothers in the fall of 2008 and the resulting liquidity crisis caused the German government to adopt a new framework for bank support. The Financial Market Support Act established a new fund, the Financial Market Stabilization Fund (Sonderfonds Finanzmarktstabilisierung, “SoFFin”), to provide up to €400 billion of guarantees on newly issued unsubordinated debt instruments of German financial institutions and German subsidiaries of foreign financial institutions. SoFFin also provided support through recapitalizations and asset purchases, in addition to guarantees. The scheme was extended multiple times before the issuance window closed initiall...