Agencies Provide Model Template For Submission Of Tailored Resolution Plans

The Federal Reserve Board and the Federal Deposit Insurance Corporation, or FDIC, have released an optional model template for tailored resolution plans that certain firms will be submitting for the first time later this year.

The Dodd-Frank Wall Street Reform and Consumer Protection Act requires that bank holding companies with total consolidated assets of $50 billion or more and nonbank financial companies designated for enhanced prudential supervision by the Financial Stability Oversight Council submit resolution plans to the Federal Reserve and the FDIC. The initial resolution plans for one group of firms–generally those with less than $100 billion in total nonbank assets or $100 billion in U.S. nonbank assets if they are a foreign-based company–must be submitted to the Federal Reserve and the FDIC on or before December 31.

The resolution plan rule previously issued by the agencies permits eligible firms, generally those that are smaller and less complex, to file a tailored resolution plan. A tailored resolution plan focuses on the nonbanking operations of the firm and on the interconnections and interdependencies between the nonbanking and banking operations. The optional template is intended to facilitate the preparation of tailored resolution plans.


DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

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