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Agencies Provide Additional Instructions for Submission of Resolution Plans and Extend Deadline

On April 15 the Federal Reserve Board (Board) and the Federal Deposit Insurance Corporation (FDIC) announced the release of additional guidance, clarification and direction for the first group of institutions filing their resolution plans pursuant to the Dodd-Frank Wall Street Reform and Consumer Protection Act. These 11 institutions filed their initial resolution plans with the Federal Reserve Board and the FDIC in 2012. Plans were required generally from US bank holding companies with $250 billion or more in total nonbank assets and foreign-based bank holding companies with $250 billion or more in total US nonbank assets. Following review of the initial resolution plans, the agencies have developed instructions for the firms to detail what information should be included in their 2013 resolution plan submissions. In particular, “the revised instructions include requests for more detailed information on, and analysis of, obstacles to resolvability under the Bankruptcy Code including global issues, financial market utility interconnections, and funding and liquidity, as well as to provide analysis to support the strategies and assumptions contained in the firms’ resolution plans.”

The Board and the FDIC have also granted an extension to the filing date to give the firms additional time to develop resolution plan submissions that address the agencies’ instructions. Accordingly, the 2013 resolution plan filing deadline will move from July 1, 2013 to October 1, 2013. The extension does not affect resolution plan submission dates for other banking organizations.

More information is available here and here.

©2014 Katten Muchin Rosenman LLP

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