Federal Banking Regulators Post Public Segments of Resolution Plans

The Board of Governors of the Federal Reserve System ("FRB") and the Federal Deposit Insurance Corporation ("FDIC") posted the public portions of the annual resolution plans of 12 large financial firms.

Pursuant to the Dodd-Frank Act, the FRB and FDIC require plans to be divided appropriately into public and confidential sections, as determined by the firms themselves. Previously, the FRB and FDIC issued guidance requiring the firms to provide more detailed disclosure through (i) "a discussion of the strategy for resolving each material entity in a manner that mitigates systemic risk," (ii) "a high-level description of what the firm would look like following resolution," (iii) "a description of the steps that each firm is taking to improve its ability to be resolved in an orderly manner in bankruptcy" and (iv) "more detail on each material entity, such as the type of business conducted, interconnectedness among entities, and a general indication of capital and funding sources."

Although the FRB and FDIC have yet to review the resolution plans in their entirety, the public portions of the plans have been posted on the FDIC and FRB Web sites.

See: FRB/FDIC Press Release.