Canine Portosystemic Shunt: Medical and Surgical Management

By Dr. Zubair Khalid, DVM, MS, PhD ·

Canine Portosystemic Shunt: Medical and Surgical Management

Key Takeaways

  • Medical management of canine portosystemic shunts (PSS) focuses on controlling clinical signs and reducing hepatic encephalopathy risk through dietary protein restriction, lactulose, and antimicrobials like neomycin or metronidazole, but it is palliative and rarely curative.
  • Surgical attenuation aims to restore hepatic perfusion via gradual occlusion methods (ameroid constrictors, cellophane banding) or acute ligation, with gradual methods generally offering a safer profile by allowing hepatic adaptation and reducing postligation neurologic dysfunction.
  • Preoperative stabilization is critical for surgical candidates, requiring control of clinical signs, particularly neurologic deficits, before anesthesia to minimize perioperative decompensation.
  • Postoperative complications include postligation neurologic dysfunction (PLND), hypoglycemia, and ascites, necessitating close monitoring of neurologic status, blood glucose, and abdominal girth, with prompt intervention for seizures and metabolic derangements.
  • Prognostic indicators for surgical outcome in intrahepatic shunts include body weight, total protein, albumin, and blood urea nitrogen for short-term survival, and packed cell volume and total protein for long-term survival.
  • Serial monitoring of serum bile acids and fasting ammonia concentrations postoperatively is essential to assess shunt closure and hepatic adaptation, though resolution of clinical signs is often prioritized over complete biochemical normalization.

This article compares medical and surgical management of congenital portosystemic shunts (PSS) in dogs, with emphasis on preoperative stabilization, surgical decision-making, and postoperative care. It is written for practicing veterinarians who have already established the diagnosis and now face the central therapeutic question: which patients benefit from medical therapy alone, which require surgical attenuation, and how should each pathway be executed and monitored? Diagnostic imaging is excluded by design, the focus rests entirely on treatment strategy, patient selection, and outcome optimization.

The evidence base for PSS management draws from retrospective case series, expert consensus, and institutional experience. Prospective randomized trials are scarce, and much of the published literature reports single-center outcomes with modest sample sizes. The clinician should therefore interpret survival figures and complication rates as directional instead of definitive, and should weigh them against the individual patient's shunt anatomy, clinical severity, and owner commitment. The ACVIM consensus statements provide structured guidance where primary literature is insufficient, and the MSD Veterinary Manual offers practical pharmacology and monitoring reference for the drugs discussed below.

At a Glance

ParameterMedical ManagementSurgical Management
Primary goalControl clinical signs, reduce encephalopathy riskGradual or complete shunt attenuation to restore hepatic perfusion
Candidate selectionPoor surgical candidates, severe hepatopathy, owner constraintsMost congenital PSS, especially young dogs with controlled signs
Preoperative requirementNot applicableStabilization with medical therapy before surgery
Encephalopathy controlProtein restriction, lactulose, antimicrobials, antiseizure drugsSame medical measures, continued perioperatively
Shunt occlusion methodNoneAmeroid constrictor, cellophane banding, suture ligation, or intravascular devices
Expected outcomeClinical improvement in many, but signs often recur or persistGood to excellent in most survivors, with diet and medication often discontinued
Major failure modeProgressive encephalopathy, urolithiasis, poor quality of lifePostligation neurologic dysfunction, seizures, portal hypertension

Pathophysiology Relevant to Treatment Decisions

Congenital PSS diverts portal blood past the liver, depriving hepatocytes of trophic factors and allowing intestinally derived toxins to reach the systemic circulation. The resulting hepatic atrophy is partially reversible once portal flow is restored, which explains why surgical attenuation can produce lasting improvement even in mature dogs. The liver's capacity to adapt to increased portal flow after shunt occlusion is a primary determinant of outcome, a principle recognized across species in the comparative surgical literature on portosystemic shunt diagnosis and treatment.

The clinical syndrome reflects both hepatic insufficiency and toxin exposure. Ammonia, mercaptans, aromatic amino acids, and endogenous benzodiazepine-like substances contribute to hepatic encephalopathy, while reduced hepatic metabolism of drugs and hormones produces additional systemic signs. Urolithiasis, particularly ammonium biurate stones, arises from hyperammonemia and altered purine metabolism, and may persist or recur even after successful shunt attenuation. Understanding these downstream effects informs monitoring priorities: liver function tests, neurologic status, and urinary tract surveillance all belong in the follow-up plan.

Medical Management: Principles and Limitations

Medical therapy targets the consequences of shunting instead of the shunt itself. Dietary protein restriction reduces ammoniagenic substrate, lactulose acidifies colonic contents and promotes nitrogen excretion, and antimicrobials such as neomycin or metronidazole reduce urease-producing gut flora. Antiseizure medications, typically levetiracetam or phenobarbital, may be required for refractory encephalopathic seizures. Current formulary and label references must be consulted for dosing, as published protocols vary and individual patient tolerance differs.

Medical management can alleviate clinical signs for months to more than a year in a substantial proportion of dogs, as documented in early case series of congenital portosystemic encephalopathy. However, the same series reported that surgical ligation succeeded in only half of the dogs in which it was attempted, and medical therapy alone rarely produces permanent resolution. The clinician should frame medical management as either a bridge to surgery or a palliative strategy for patients in which surgery is declined or contraindicated, not as a curative alternative.

Surgical Management: Occlusion Techniques and Patient Selection

Surgical attenuation aims to redirect portal blood through the hepatic parenchyma, allowing hepatocyte regeneration and gradual normalization of liver function. Techniques differ in the speed and completeness of occlusion. Acute suture ligation achieves immediate, complete closure but carries the highest risk of portal hypertension and postligation neurologic dysfunction. Gradual occlusion methods, including ameroid constrictors and cellophane banding, narrow the vessel progressively over weeks, permitting hepatic adaptation and reducing acute complications.

Ameroid constrictor placement for intrahepatic shunts has been reported with low complication rates and no observed postligation neurologic dysfunction in a small retrospective series, with most animals returning to a non-prescription diet without medication. Cellophane banding achieves similar gradual occlusion and has been used successfully in cats, though the same study reported refractory seizures as the most common cause of death after the procedure. These findings illustrate a consistent theme: gradual attenuation is generally safer than acute ligation, but neurologic complications remain possible and must be anticipated.

Patient selection influences outcomes substantially. Dogs aged five years and older can still benefit from surgical attenuation, with serum bile acids and ammonia concentrations nearly normalizing in a majority of survivors, although concurrent disease and perioperative mortality remain concerns. Prognostic indicators for intrahepatic shunts include body weight, total protein, albumin, and blood urea nitrogen for short-term outcome, and packed cell volume and total protein for long-term survival. These parameters help the surgeon identify high-risk patients before committing to intervention.

Preoperative Stabilization

Surgery should not proceed until medical therapy has controlled clinical signs, particularly neurologic signs. The duration of stabilization varies with disease severity, but the goal is a patient that is eating, neurologically stable, and free of active seizure activity. Preoperative management typically combines dietary modification, lactulose, antimicrobials, and supportive care, with the intensity titrated to the patient's condition. Dogs with severe encephalopathy or seizures may require hospitalization, intravenous fluids, and more aggressive antiseizure therapy before anesthesia is considered.

The importance of this phase is underscored by the comparative literature: medical management stabilizes critical patients in anticipation of surgery and remains the only option when surgical correction is not feasible. A dog that cannot be stabilized medically is a poor surgical candidate, and proceeding with attenuation in such a patient invites postoperative decompensation. Conversely, delaying surgery excessively while the patient remains stable on medical therapy offers little benefit, since the underlying shunt persists and clinical signs will likely recur.

Postoperative Care and Complication Management

The immediate postoperative period after shunt attenuation demands close monitoring for hemodynamic instability, seizures, and hypoglycemia. Patients should be maintained on intravenous fluids with dextrose supplementation until they are eating reliably. Analgesia is provided with opioids and nonsteroidal anti-inflammatory drugs are avoided in the first 48 hours given concerns about hepatic perfusion and platelet function. Body temperature, blood glucose, packed cell volume, and total protein are assessed every 6 to 8 hours for the first 24 hours.

Postligation neurologic dysfunction (PLND) remains the most feared complication. It manifests as seizures, stupor, or coma within 72 hours of surgery and carries a guarded prognosis. In one series of cats undergoing cellophane banding, refractory seizures were the most common cause of death, with two of nine cats euthanized within 3 days of the procedure. Dogs with intrahepatic shunts appear similarly at risk, although ameroid constrictor placement was associated with a low complication rate and no observed postligation neurologic dysfunction in one retrospective study. Treatment of PLND begins with levetiracetam or propofol infusion for seizure control, lactulose administered per rectum, and correction of any metabolic derangements. The evidence base for specific anticonvulsant protocols is limited, and current formulary references should guide drug selection and dosing.

Hypoglycemia occurs because the liver's capacity for gluconeogenesis and glycogen storage is reduced. Serial blood glucose measurement is mandatory, and persistent hypoglycemia despite dextrose supplementation warrants investigation for sepsis or inadequate hepatic perfusion. Ascites may develop when portal pressure rises acutely after attenuation. Mild transient ascites is managed with fluid restriction and spironolactone. Refractory ascites suggests excessive shunt occlusion and may require surgical revision or conversion to a slower attenuation method.

Monitoring Parameters and Reassessment

Serial clinicopathologic monitoring tracks the liver's adaptation to increased portal flow. Serum bile acids and fasting ammonia concentrations are the most useful functional tests, although they do not always normalize completely. In dogs aged 5 years and older that underwent extrahepatic shunt attenuation, bile acids almost normalized in 5 of 8 dogs at a median of 23 months, and ammonia was within reference limits in 3 of 5 dogs, with no associated clinical signs in those with persistent abnormalities. This pattern supports a pragmatic approach: resolution of clinical signs matters more than biochemical normalization.

ParameterTimingWhat It DetectsAction Threshold
Blood glucoseEvery 6 to 8 hours for 48 hoursHypoglycemia from reduced hepatic functionTreat if below reference interval
Neurologic statusEvery 4 to 6 hours for 72 hoursPostligation neurologic dysfunctionInitiate anticonvulsant therapy
Serum bile acids3 to 6 months postoperativelyResidual shunting or inadequate attenuationRepeat imaging if clinical signs persist
Fasting ammonia3 to 6 months postoperativelyHepatic encephalopathy riskAdjust medical therapy
Abdominal girthDailyAscites from portal hypertensionDiuretic therapy, reassess occlusion
Packed cell volume and total proteinDaily for 48 hoursHemorrhage or hemodilutionTransfusion if clinically significant

Long-term follow-up should occur at 1, 3, 6, and 12 months postoperatively, then annually. Persistent or recurrent clinical signs, particularly neurologic signs or urinary tract signs, warrant repeat bile acid testing and abdominal ultrasound to assess shunt closure. A small proportion of dogs require continued medical management despite surgery, and owners should understand that dietary protein restriction and lactulose may remain necessary.

Medical Versus Surgical Management: Decision Framework

The choice between medical and surgical management depends on shunt anatomy, patient stability, available expertise, and owner resources. Surgical attenuation offers the best chance for long-term resolution, but it carries perioperative risk. Medical management can stabilize patients and, in some cases, control signs for extended periods, but it rarely eliminates the underlying abnormality.

In a review of 21 dogs with congenital portosystemic encephalopathy, surgical ligation of an extrahepatic shunt was successful in 2 of 4 dogs, while medical management alleviated clinical signs in 5 of 8 dogs, with successful periods ranging from a few months to over a year. This early data illustrates that medical therapy can provide meaningful control, but durability is variable. For intrahepatic shunts, median survival time in one series was 35.68 months with 1- and 2-year survival probabilities of 60% and 55%, respectively. These figures reflect the era of suture attenuation and may not apply to modern ameroid constrictor or cellophane banding techniques.

FactorFavor Medical ManagementFavor Surgical Management
Shunt anatomyMultiple acquired shunts, diffuse microvascular dysplasiaSingle congenital extrahepatic or intrahepatic shunt
Patient stabilitySevere hepatic encephalopathy, uncontrolled seizuresStable after preoperative stabilization
AgeVery young (< 4 months) or geriatric with comorbidities4 months to 5 years, otherwise healthy
Owner resourcesLimited budget, unable to provide intensive postoperative careAble to commit to postoperative monitoring
Available expertiseNo surgeon experienced in shunt attenuationExperienced soft tissue surgeon available
Concurrent diseaseSevere coagulopathy, portosystemic shunt with other congenital defectsNo significant concurrent disease

Medical management is the primary option when surgical correction is not possible, as noted in the feline literature. It is also appropriate for patients with acquired shunts secondary to portal hypertension, where surgical attenuation is contraindicated. For congenital shunts, surgery should be recommended when the patient is stable enough to tolerate anesthesia and the surgeon has experience with the chosen attenuation technique.

Long-Term Outcomes and Prognostic Indicators

Prognostic indicators for intrahepatic shunt attenuation include body weight, total protein, albumin, and blood urea nitrogen for short-term outcome, and packed cell volume and total protein for long-term survival. These parameters reflect the patient's nutritional and metabolic reserve at the time of surgery. Dogs with low body weight, hypoalbuminemia, and low blood urea nitrogen have a higher risk of perioperative complications and poorer long-term survival.

Age at surgery influences outcome. Dogs aged 5 years and older can still benefit from surgical attenuation, but they carry a higher risk of perioperative death and may have persistent biochemical abnormalities. Older dogs are more likely to have concurrent disease, including urinary tract calculi and bacterial infections, which complicate recovery.

Owner perception of outcome is generally favorable after successful attenuation. In the ameroid constrictor series, clinical signs resolved in 7 of 9 dogs and owners were able to discontinue prescription diets and medications. However, a minority of dogs continue to experience hepatic encephalopathy despite surgery, and these cases require ongoing medical management. The decision to pursue surgery should therefore include a frank discussion of expected outcomes, the possibility of incomplete resolution, and the financial commitment involved.

Documentation and Case Recording

Accurate documentation supports clinical decision-making and outcome assessment. The medical record should include the preoperative bile acid and ammonia values, imaging findings that characterize shunt anatomy, the surgical technique used, the degree of attenuation achieved, and intraoperative complications. Postoperative records should document neurologic status, blood glucose measurements, and any interventions for complications. At each recheck, record the current diet, medications, and the presence or absence of clinical signs. This longitudinal record allows the clinician to distinguish between incomplete attenuation, shunt recanalization, and the development of acquired shunts when clinical signs recur.

Recognized Complications and Early Detection

Postoperative deterioration after shunt attenuation follows recognizable patterns. Acute portal hypertension develops when occlusion is too rapid or the hepatic vasculature cannot accommodate increased portal flow. Clinical signs include abdominal pain, vomiting, hypotension, and a rising packed cell volume from splanchnic sequestration. Detection depends on serial assessment of perfusion parameters, abdominal palpation, and packed cell volume trends in the first 24 to 48 hours after surgery.

Postligation neurologic dysfunction (PLND) is the most feared complication. It presents as seizures, stupor, or coma beginning 24 to 72 hours postoperatively, sometimes after initial apparent recovery. The mechanism is not fully understood but likely involves altered cerebral blood flow, neurotransmitter shifts, or both. In one series of intrahepatic shunts occluded with ameroid constrictors, postligation neurologic dysfunction was not observed, whereas in a feline cellophane banding series, refractory seizures were the most common cause of death within the early postoperative period. This discrepancy underscores that technique and species influence risk. Early detection relies on frequent neurologic checks, prompt recognition of restlessness or pacing as prodromal signs, and immediate institution of anticonvulsant and hepatic encephalopathy therapy when signs appear.

Hemorrhage from the surgical site or from portal hypertension-induced varices can occur. Serial packed cell volume and ultrasound assessment of the abdomen help distinguish surgical bleeding from other causes of hypotension. Ascites may develop days to weeks after attenuation, reflecting persistent portal hypertension or hypoalbuminaemia.

Seizures that begin weeks after surgery, instead of in the immediate postoperative window, raise concern for acquired portosystemic shunting, incomplete occlusion, or unrelated intracranial disease. Recurrent hepatic encephalopathy after initial improvement suggests inadequate shunt closure or development of acquired shunts.

Common Errors and Corrective Actions

Less experienced clinicians often mistake preoperative medical stabilization for a substitute for definitive treatment. Medical management controls signs but does not address the underlying shunt. In one early review, medical management alleviated clinical signs in 5 of 8 dogs, but the period of successful treatment ranged from a few months to over a year, indicating that long-term control is unreliable.

A second error is discharging a patient before confirming adequate shunt occlusion. Postoperative bile acid testing should be performed at a scheduled reassessment, not deferred indefinitely. Dogs with persistent elevations may be clinically normal, but they remain at risk for recurrent encephalopathy and urolithiasis.

Underestimating the significance of preoperative hypoalbuminaemia and low total protein is another mistake. These variables have been identified as prognostic indicators for short-term outcome in dogs with intrahepatic shunts, and their presence should prompt more cautious surgical planning and more intensive postoperative monitoring.

Students and trainees frequently misinterpret postprandial bile acid results without paired fasting samples, or they attribute all neurologic signs to hepatic encephalopathy without considering hypoglycemia, seizures from other causes, or PLND. A systematic approach to the postoperative neurologic patient, including blood glucose measurement and assessment of seizure character, prevents misdiagnosis.

Troubleshooting Table

ObservationLikely CauseDiscriminating Check
Tachycardia, pale mucous membranes, rising PCV within 24 hours postopAcute portal hypertension or hemorrhageAbdominal ultrasound for free fluid, serial PCV and blood pressure
Seizures 24 to 72 hours postopPostligation neurologic dysfunctionBlood glucose, ammonia, neurologic examination, exclude hypoglycemia first
Ascites developing days after surgeryPortal hypertension, hypoalbuminaemiaSerum albumin, abdominal ultrasound, transudate analysis
Recurrent encephalopathy weeks laterIncomplete occlusion or acquired shuntsPostprandial bile acids, ammonia, repeat imaging
Persistent ptyalism or vomiting after apparent recoveryResidual shunting or gastrointestinal ulcerationBile acid testing, gastrointestinal evaluation

Limitations of Current Evidence

The published literature on portosystemic shunt management consists largely of retrospective case series with small numbers and variable follow-up. Direct comparisons between medical and surgical management are scarce, and randomised prospective trials are absent. Reported outcomes differ substantially between studies, partly because of differences in shunt location, attenuation technique, and follow-up duration. For example, median survival time in one intrahepatic shunt series was 35.68 months with 1- and 2-year survival probabilities of 60% and 55%, while another series reported that 7 of 9 dogs with intrahepatic shunts had resolution of clinical signs after ameroid constrictor placement. These figures are not directly comparable because the populations and techniques differ.

Expert opinion still differs on several points. The optimal degree of acute attenuation remains contested, with some surgeons favouring complete ligation when tolerated and others preferring gradual occlusion devices for all cases. The role of intraoperative portal pressure measurement is debated, and no consensus threshold has been universally accepted. The management of dogs with acquired shunts or concurrent hepatic fibrosis is similarly unsettled.

Referral and Consultation Criteria

Referral to a surgical specialist is warranted for intrahepatic shunts, which carry higher perioperative risk and require advanced surgical exposure. Dogs with preoperative hypoalbuminaemia, low total protein, or low body weight merit referral because these factors predict worse short-term outcomes. Patients that fail to stabilize medically within 7 to 14 days, or that develop refractory encephalopathy despite appropriate therapy, should be referred before decompensation becomes irreversible.

Specialist consultation with an internal medicine diplomate is appropriate when medical management is failing, when the diagnosis is uncertain, or when concurrent hepatobiliary disease complicates treatment. Laboratory involvement is indicated for histopathology of liver biopsy samples obtained at surgery, for bile acid assay validation, and for ammonia measurement where point-of-care testing is unreliable.

Regulatory reporting is rarely relevant to congenital portosystemic shunt management in companion animals. However, clinicians should be aware that inherited predisposition is recognized in certain breeds, and breeding advice should be offered to owners. Where national veterinary bodies or breed registries maintain health screening schemes, participation may be appropriate.

Frequently Asked Questions

How should I manage a dog with a portosystemic shunt when surgical referral is not financially feasible?

Medical management becomes the primary strategy when surgery is declined or unavailable. The goal is to reduce ammoniagenic substrate delivery to the colon and limit protein load. Dietary protein restriction with a highly digestible, moderate-protein prescription diet forms the foundation. Lactulose and antimicrobial therapy directed at urease-producing gut flora are added when clinical signs persist. Maddison's review of congenital portosystemic encephalopathy reported that medical management alleviated clinical signs in 5 of 8 dogs, though the duration of successful control ranged from months to just over a year. Owners should understand that medical therapy is palliative, not curative, and that neurologic signs may recur despite compliance. Recheck evaluations should include bile acids, ammonia, and body condition scoring at regular intervals.

What is the role of lactulose in managing hepatic encephalopathy, and how is efficacy assessed?

Lactulose is a nonabsorbable disaccharide that acidifies colonic contents, trapping ammonia as ammonium ion and promoting its fecal excretion. It also exerts a cathartic effect that reduces colonic transit time and bacterial substrate exposure. Efficacy is assessed clinically by resolution or reduction of neurologic signs, not by laboratory values alone. The dose is titrated to produce two to three soft stools daily. Overdosing causes diarrhea, dehydration, and electrolyte losses, which can paradoxically worsen encephalopathy. Underdosing leaves ammonia production unchecked. The MSD Veterinary Manual provides dosing guidance for lactulose in hepatic encephalopathy, but current formulary references should be consulted for specific recommendations. In hospitalized patients, response to lactulose is typically seen within 12 to 24 hours when combined with other supportive measures.

When is medical management preferred over surgery as the definitive long-term plan?

Medical management becomes the definitive plan when surgical attenuation is contraindicated, declined, or technically impossible. Older dogs with concurrent cardiopulmonary disease, severe hepatic fibrosis, or coagulopathies may be poor surgical candidates. Worley and Holt's case series of dogs aged five years and older showed that surgery was feasible in this population, but two of seventeen dogs died postoperatively, and long-term survival was influenced by unrelated comorbidities. Medical management may also be selected for dogs with multiple acquired shunts, where attenuation of a congenital shunt could precipitate portal hypertension. In these situations, the owner must accept that clinical signs may be controlled but not eliminated. Periodic reassessment is mandatory because medical control can wane over time, and the decision to revisit surgical options should remain open.

How does the treatment approach differ between extrahepatic and intrahepatic shunts?

Extrahepatic shunts are more accessible surgically and are often amenable to ameroid constrictor placement or cellophane banding. Intrahepatic shunts require more invasive dissection, and the risk of hemorrhage and postligation neurologic dysfunction is higher. Bright and colleagues reported that ameroid constrictor placement for intrahepatic shunts produced a low complication rate with no observed postligation neurologic dysfunction in nine dogs and one cat, with most animals returning to a non-prescription diet without medication. However, Papazoglou and colleagues identified prognostic indicators for intrahepatic shunts including body weight, total protein, albumin, and blood urea nitrogen for short-term outcome, with median survival of 35.68 months. Preoperative stabilization is identical for both locations, but intrahepatic shunts warrant more cautious intraoperative decision-making regarding the degree of attenuation.

What should I record in the medical record for a shunt case to support continuity of care?

Document the presenting neurologic, gastrointestinal, and urinary signs with a standardized grading scale for encephalopathy. Record baseline bile acids, ammonia, albumin, glucose, and urinalysis findings. For surgical cases, note the shunt location, the attenuation method used, the degree of occlusion achieved, and intraoperative portal pressure measurements if obtained. Postoperative records should track neurologic status at fixed intervals, appetite, and any seizure activity. The AVMA practice resources emphasize that complete medical records support patient safety and continuity across referral transitions. Include owner communication summaries, particularly discussions of prognosis, cost estimates, and the expected timeline for clinical improvement. Serial bile acid measurements at three, six, and twelve months postoperatively provide objective evidence of shunt closure and should be recorded alongside clinical status.

How do I explain the treatment options and prognosis to an owner in a balanced, honest way?

Present medical and surgical management as complementary instead of competing strategies. Explain that medical therapy stabilizes the patient and controls signs, while surgery addresses the underlying anatomy. Use the analogy of a detour: medical management reduces traffic on the road, surgery removes the detour entirely. Cite the realistic outcomes from the literature. Tillson and Winkler's review of portosystemic shunts notes that medical management stabilizes critical patients in anticipation of surgery and is used when surgical correction is not possible. Be explicit about the risks: anesthesia, hemorrhage, seizures, and the possibility that attenuation may be incomplete. Discuss the financial commitment for both options, including recheck laboratory work and potential complications. Give the owner a written summary of the discussion and allow time for questions before asking for a decision.

Related Clinical & Scientific Guides

References and Further Reading

Related Articles

This article is educational professional reference material for veterinary audiences. It is not a substitute for veterinary diagnosis, individual clinical judgment, current product labeling, or applicable regulatory requirements.