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    FED Issues Supporting Statement for Regulation QQ on Resolution Plans

    August 27, 2018

    FED published supporting statement for the reporting requirements associated with Regulation QQ (FR QQ; OMB No. 7100-0346) on resolution plans. On August 21, 2018, FED had published the final Federal Register Notice on the adoption of the proposal to extend, with revision, the mandatory reporting requirements associated with Regulation QQ. The revisions are applicable as of July 31, 2018.

    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. Resolution plans filed under section 165(d) and Regulation QQ assist covered companies and regulators in conducting advance resolution planning for a covered company. Regulation QQ requires a strategic analysis by the covered company of how it can be resolved under the Bankruptcy Code within a reasonable period of time and in a manner that substantially mitigates the risk that the failure of the covered company would have serious adverse effects on financial stability in the United States. Regulation QQ requires each resolution plan to contain certain information, including information on the

    • Manner and extent to which any insured depository institution affiliated with the covered company is adequately protected from risks arising from the activities of nonbank subsidiaries of the company
    • Detailed descriptions of the ownership structure, assets, liabilities, and contractual obligations of the company
    • Identification of the cross-guarantees tied to different securities and identification of major counterparties
    • A process for determining to whom the collateral of the company is pledged 

     

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    Keywords: Americas, US, Banking, Reporting, Regulation QQ, Resolution Planning, Supporting Statement, EGRRCP Act, FED

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