As most private equity professionals are aware, in the spring of 2013, the Federal Reserve Board, the Federal Deposit Insurance Corp. and the Office of the Comptroller of the Currency (collectively, the “agencies”) issued the final version of their Interagency Guidance on Leveraged Lending. The guidance includes two critical metrics: (1) a borrower should be able to fully amortize its senior secured debt, or a significant portion (e.g., 50%) of its total debt, over the medium term (i.e., five to seven years) using free cash flow and (2) borrower leverage levels of greater than 6x total debt to earnings before interest, taxes, depreciation, and amortization (EBITDA) “raise concerns” for borrowers in “most industries.”