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August 21, 2018

FED adopted the proposal to extend, with revision, the mandatory reporting requirements associated with Regulation QQ (Form Reg QQ; OMB No. 7100-0346). Regulation QQ applies to bank holding companies with assets of USD 50 billion or more and nonbank financial firms that have been designated for FED supervision. These entities are required to annually report to FED and FDIC their plans for rapid and orderly resolution under the U.S. Bankruptcy Code, in the event of material financial distress or failure. The consultation ran from January to March 2018. The revisions are applicable as of July 31.

FED had proposed to revise its original burden estimates based on a reassessment of the burden hours associated with responding to the informational requirements of Regulation QQ and to guidance, feedback, and additional requests for information by the agencies as part of the iterative resolution planning process. The increase in burden is mitigated by the postponement of the July 2018 submission date for the resolution plans of the complex domestic filers, which account for the largest percentage of overall burden hours.

FED received one comment on the proposal. The respondent recommended a number of potential changes to Regulation QQ; the changes were intended to enhance the quality of the information collected and to reduce the burden of the information collection requirements. FED is not adopting any of the recommended changes. Either a revision to the Regulation QQ of FED or a joint action with FDIC would be necessary to implement the recommended changes. However, FED will consider the recommended changes in due course, as it determines, in consultation with the FDIC, whether to conduct a joint rule making. 

 

Related Link: Federal Register Notice

Keywords: Americas, US, Reporting, Regulation QQ, Bank Regulation, Resolution Planning, FED

 

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