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    US Agencies Release Public Sections of Resolution Plans of Large Banks

    July 23, 2019

    US Agencies (FDIC and FED) released public sections of the resolution plans of eight large domestic firms. These domestic firms are Bank of America Corporation, Bank of New York Mellon Corporation, Citigroup Inc., Goldman Sachs Group, JPMorgan Chase & Co., Morgan Stanley, State Street Corporation, and Wells Fargo & Company. Resolution plans describe the strategy for rapid and orderly resolution under bankruptcy, in the event of material financial distress or failure.

    Dodd-Frank Act requires that bank holding companies with consolidated assets of USD 50 billion or more and non-bank financial companies designated by the Financial Stability Oversight Council (FSOC) for supervision by FED periodically submit resolution plans to the US Agencies. Each plan, commonly known as a living will, must describe the strategy for rapid and orderly resolution under the U.S. Bankruptcy Code, in the event of material financial distress or failure of the company. Companies subject to the rule are required to file their resolution plans on a staggered schedule. The largest bank holding companies are required to submit their plans on or before July 01 each year. This group comprises domestic companies with USD 100 billion or more in non-bank assets and foreign-based companies with USD 100 billion or more in U.S. non-bank assets. Non-bank financial companies that are designated by FSOC also must submit on or before July 01. All other firms are required to submit their plans on or before December 31 each year. Requests for extensions are reviewed by the US Agencies. 

     

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    Keywords: Americas, US, Banking, Resolution Plans, Living Will, Dodd-Frank Act, Large Banks, FSOC, US Agencies

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