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Heat Turned Up Over US Living Wills

In a sign that the political tide may be turning, the FT is reporting that the Federal Reserve and the Federal Deposit Insurance Corporation have raised the prospect of taking severe action against banks that submit deficient living wills, including increased capital requirements or even forced break-ups. Whereas previously, it was accepted that RRP was […]

“Key Attributes of Effective Resolution Regimes”: a Case of the Emperor’s New Clothes?

The FT is reporting that the Federal Reserve and the Federal Deposit Insurance Corporation have warned banks which are required to produce Recovery and Resolution Plans (RRP) not to assume that regulators will co-operate to avoid the failure of a financial group.  In contrast, they are being required to detail the types of legal filings, […]

FDIC and BoE Publish Strategy Paper on Resolution Plans

Introduction On 10 December 2012, the Federal Deposit Insurance Corporation (FDIC) and the Bank of England (BOE) published a joint strategy paper on the resolution of globally active, systemically important, financial institutions (G-SIFIs). Broadly speaking, there are two main approaches to the resolution of G-SIFIs: “Single point of entry” (or “top down”) resolution pursuant to […]

FDIC Publishes Resolution Plans for Systemically Important Financial Institutions

As required by Parts 360.10 and 381.8(c) of Title 12 of the Code of Federal Regulations, the resolution plan of every insured depository institution with USD 50 billion or more in total assets and every systemically important financial institution is required to split into a public section and a private section.  The Federal Deposit Insurance Corporation […]

Large Banks Submit First Resolution Plans Under Dodd-Frank

2 July 2012 was the deadline for nine of the largest US and foreign banks to submit their first resolution plans to the FDIC and the Federal Reserve Board pursuant to requirements enacted under the Dodd-Frank Act.  An executive summary of each resolution plan will be published by close of business on 3 July 2012.  […]

BoE, FSA and FDIC Plan “Top Down” Bail-In of Seven G-SIFIs

Below is a link to an FT article published this morning which discusses the progress being made by authorities in the UK and the US on the drafting of resolution plans for seven of the twenty-nine G-SIFIs, including Goldman Sachs, JP Morgan and Barclays. Of more interest is the fact that the UK and US […]

FDIC approves final rule requiring resolution plans

On 17 January 2012 the Federal Deposit Insurance Corporation (the “FDIC”) approved a final rule requiring insured depository institutions with USD 50 billion or more in total assets to periodically submit to the FDIC contingency plans for resolution in the event of the institution’s failure.  This rule follows a separate final ruling, adopted jointly by […]

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