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Agencies Provide Additional Instructions for Submission of Some Resolution Plans
The Federal Reserve Board (Board) and the Federal Deposit Insurance Corporation (FDIC) on Monday announced the release of additional guidance, clarification and direction for the first group of institutions filing their resolutions plans pursuant to the Dodd-Frank Act.
These 11 institutions filed their initial resolution plans with the Federal Reserve Board and the FDIC in 2012. Plans were required generally from U.S. bank holding companies with $250 billion or more in total nonbank assets and foreign-based bank holding companies with $250 billion or more in total U.S. nonbank assets. Following review of the initial resolution plans, the agencies have developed instructions for the firms to detail what information should be included in their 2013 resolution plan submissions.
In particular, the revised instructions include requests for more detailed information on, and analysis of, obstacles to resolvability under the Bankruptcy Code including global issues, financial market utility interconnections, and funding and liquidity, as well as to provide analysis to support the strategies and assumptions contained in the firms’ resolution plans.
The Board and the FDIC have also granted an extension to the filing date to give the firms additional time to develop resolution plan submissions that address the agencies’ instructions. Accordingly, the 2013 resolution plan filing deadline will move from July 1, 2013, to October 1, 2013. The extension does not affect resolution plan submission dates for other banking organizations.
The agencies expect that the submission of increasingly comprehensive resolution plans will facilitate a more robust and effective resolution planning process. As in 2012, the Board and the FDIC will post the public sections of the resolution plans to their websites.
The additional guidance can be found on the FDIC website at:
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