FRB and FDIC Provide Feedback on Second Round of Orderly Resolution Plans

The Board of Governors of the Federal Reserve System ("FRB") and the FDIC announced the completion of their reviews of the second round of resolution plans submitted by 11 large, complex banking organizations in 2013. Each resolution plan, commonly known as a "living will plan," must describe the company's strategy for effecting a rapid and orderly resolution in the event of material financial distress or failure of the company.

The 11 banking organizations in the first group of filers included Bank of America, Bank of New York Mellon, Barclays, Citigroup, Credit Suisse, Deutsche Bank, Goldman Sachs, JPMorgan Chase, Morgan Stanley, State Street Corp. and UBS. The FRB and FDIC issued letters to these "first-wave" filers regarding each specific plan, setting forth specific shortcomings and expectations for 2015.

Additionally, the agencies note some improvement since the original plans were submitted by the "first-wave filers" in 2012, including new attempts to address the five obstacles identified in guidance issued by the FRB and FDIC in April 2013.

See: FRB-FDIC Joint Release.Related news: FRB Provides Additional Information for Large Bank Holding Companies as to Resolution Planning and Recovery (with Lofchie Comment) (January 24, 2014); Banking Agencies Release Public Sections of Resolution Plans for Banks with Less than $100 Billion in Qualifying Nonbank Assets(January 10, 2014); FDIC and FRB Release Public Sections of Second Submission of Resolution Plans for Eleven Institutions (October 3, 2013); Agencies Provide Model Template for Submission of Tailored Resolution Plans (September 3, 2013); Board and FDIC Provide Additional Instructions for Submission of Some Resolution Plans (April 15, 2013); Living Will Deadline for Non-U.S. Banks Approaching (with Cammarn Comment) (March 17, 2013).