Who Is Too Big To Fail? FDIC Doesn’t Answer Question


James R. Wigand, Director, Office Of Complex Financial Institutions and Richard J. Osterman, Jr., Acting General Counsel, of the FDIC testified before the Subcommittee on Oversight and Investigations; Committee on Financial Services; U.S. House of Representatives.

While their testimony was captioned  “Who Is Too Big To Fail? Examining the Application of Title I of the Dodd-Frank Act,” it appears they never directly addressed the question, at least if what you want is for them to name names, like most of us.

The testimony still has some useful information though.  The FDIC hasn’t just been watching large financial institutions file living wills and not doing anything.  The testimony notes “Federal Reserve Board and FDIC staff reviewed the first wave filers’ plans for informational completeness to ensure that all information requirements of the Rule were addressed in the plans.”  Hopefully they reviewed them to determine what they will do when the next crisis arrives as well.

The testimony also addressed the status of stress tests.  It notes “Certain insured institutions and bank holding companies with assets of $50 billion or more comprised the first set of companies to conduct stress tests, which were completed in March 2013. Using September 30, 2012 financial data, institutions developed financial projections under defined stress scenarios provided by the agencies in November 2012. Each company publicly disclosed the results of their stress tests on or before March 31st of this year. Institutions with assets greater than $10 billion, but less than $50 billion, and larger institutions that have not had previously conducted stress tests, will conduct their first round of stress tests later this fall.” 

Check dodd-frank.com frequently for updated information on the JOBS Act, the Dodd-Frank Act and other important securities law matters.

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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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