July 26, 2019

US Agencies (FDIC and FED) announced several resolution plan actions, including completion of their evaluations of the 2018 resolution plans for 82 foreign banks. In addition, the Agencies extended the deadline for the next resolution plans of 82 foreign banks and 15 domestic banks to July 01, 2021. This extension will give the banks additional time to prepare their plans and will help mitigate uncertainty about the filing requirements, while the US Agencies' April 2019 proposal to revise the resolution plan rule remains pending. Until the US Agencies finalize this proposal in a final rule, the current resolution plan rule continues to apply to each covered company.

The US Agencies did not identify shortcomings, which are defined as weaknesses a firm would be required to address, in the 2018 resolution plans of the 82 foreign banks. However, the Agencies are requesting additional information in the next resolution plans from seven firms—namely, HSBC Holdings Plc, BNP Paribas, Royal Bank of Canada, Banco Bilbao Vizcaya Argentaria S.A., Bank of Montreal, Banco Santander S.A., and Toronto-Dominion Bank. Additionally, the US Agencies extended the next full resolution plan submission date for four other foreign banks—Barclays PLC, Credit Suisse, Deutsche Bank AG, and UBS AGto July 01, 2021. However, these banks are still required to submit the limited plans by July 01, 2020; the limited plans should describe how these banks have addressed the shortcomings identified in December 2018 and provide updates on certain resolution projects. 


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Keywords: Americas, US, Banking, Foreign Banks, Resolution Plans, Extension of Deadline, FED, FDIC, US Agencies

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