Every systemically important financial institution (“SIFI”)1 should now begin its early-stage planning for the preparation of a resolution plan, or living will (the “Plan”). The Plan, required by section 165(d) of the Dodd-Frank Act,2 is a detailed contingency plan that describes how a SIFI that is at risk of default can be sold, broken up, or wound down quickly and effectively in a way that mitigates serious adverse effects to U.S. financial stability.

The Plan is, metaphorically speaking, one of the joints in the systemic risk regulatory framework at which three supports meet.