resolution plans

Agencies Extend Deadline for Certain Foreign Banking Organizations’ Resolution Plan Submissions

On June 8, 2016, the Federal Reserve Board and the Federal Deposit Insurance Corporation extended the deadline for Barclays PLC, Credit Suisse Group, Deutsche Bank AG, and UBS to present their upcoming resolution plans to July 1, 2017, as a result of these entities engaging in restructuring in order to be in “compliance with the Federal Reserve Board’s Intermediate Holding Company (IHC) requirement[.]” Press releasePress release.

Joint Release on Additional Guidance for Resolution Plans

On April 15, the FDIC and the Fed issued a joint release which provides additional guidance, clarification and direction for the first group of 11 institutions filing their resolution plans pursuant to the Dodd-Frank Act.   Separate guidance was issued for domestic and foreign-based institutions.  Joint Release.  Domestic Guidance.  Foreign-Based Guidance.

FDIC Makes Available Parts of Resolution Plans

On July 3, the FDIC made available the public sections of the initial resolution plans submitted to the FDIC and the Fed under Title I of the Dodd-Frank Act. Firms in this group include U.S. bank holding companies with $250 billion or more in total nonbank assets and foreign-based bank holding companies with $250 billion or more in total U.S. nonbank assets. FDIC Release.  Summaries.

Fed, FDIC Announce Due Dates for Large Bank Resolution Plans

On June 29, the Fed and the FDIC announced the process for receiving and evaluating initial resolution plans for U.S. bank holding companies with $250 billion or more in total nonbank assets and non-U.S. banking holding companies with $250 billion or more in total U.S. nonbank assets. Such bank holding companies must submit their initial resolution plans on or before July 2 and the public sections of these resolution plans will be released on July 3. Fed Release. FDIC Release.

Joint Proposed Rule on Resolution Plan Reporting

On April 12, the Fed and the FDIC released a proposed rule pursuant to Section 165(d) of the Dodd-Frank Act which would require systemically significant bank holding companies and nonbank financial companies to submit annual resolution plans and quarterly credit exposure reports. The requirements would apply to bank holding companies with consolidated assets of $50 billion or more or nonbank financial companies designated by the Financial Stability Oversight Council for supervision by the Fed. Comments must be submitted by June 10. Joint Release. Proposed Rule.

FDIC and Fed Proposed Rule on Resolution Plans and Credit Exposure Reports for Covered Systemic Organizations

On March 29, the FDIC and the Fed approved a joint notice of proposed rulemaking which would require covered systemic organizations to file and report resolution plans and credit exposure reports as required under Section 165 of the Dodd-Frank Act. Resolution plans would have to be submitted within 180 days of the effective date of the final regulation, and credit exposure reports would have to be filed 30 days after the end of each calendar quarter. Comments must be submitted within 60 days after publication in the Federal Register. FDIC Release. Proposed Rule.