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July 16, 2018

US Agencies (FED and FDIC) are inviting comments on proposed guidance for the 2019 and subsequent resolution plan submissions by the eight largest, complex U.S. banking organizations (Covered Companies). The proposed guidance is meant to assist these firms in developing their resolution plans, which are required to be submitted pursuant to Section 165(d) of the Dodd-Frank Act. Comments should be received by September 14, 2018.

The proposed guidance, which is largely based on prior guidance issued to these Covered Companies, describes the Agencies' expectations regarding a number of key vulnerabilities in plans for an orderly resolution under the U.S. Bankruptcy Code. The guidance is organized into six substantive areas, consistent with the guidance the Agencies provided to Covered Companies in April 2016 to assist in the development of their 2017 resolution plans. These areas are capital, liquidity, governance mechanisms, operational, legal entity rationalization and separability, and derivatives and trading activities). The proposed guidance also updates certain aspects of prior guidance based on the Agencies' review of these firms' recent resolution plan submissions. The proposed revisions to the guidance are intended to streamline the firms' submissions and to provide additional clarity. The Agencies invite public comment on all aspects of the proposed guidance.

 

Related Link: Federal Register Notice

Comment Due Date: September 14, 2018

Keywords: Americas, US, Banking, Resolution Planning, Guidance, Dodd Frank Act, FED, FDIC, US Agencies

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