Agencies’ regional bank resolution feedback and FBO guidance

On March 24th, the Federal Reserve and Federal Deposit Insurance Corporation (collectively, the Agencies) released long-awaited feedback on the 2015 resolution plans for 16 US regional banks. Unlike the Agencies’ highly critical feedback to the 2015 plans filed by the eight US Global Systemically Important Banks (GSIBs), none of the 16 regional banks’ 2015 resolution plans were deemed “not credible,” and only one bank had shortcomings. In addition, the Agencies simultaneously announced that they have provided new guidance and further extended the deadline for the four largest Foreign Banking Organizations’ (FBOs) next resolution plan filing (now due on July 1st, 2018). 

  1. No deficiencies across the board, but greater feedback and guidance to two regional banks. 
  2. Option for streamlined 2017 submissions.
  3. Updated guidance for regional banks’ 2017 plans. 
  4. Five regional banks need to incorporate more severe financial assumptions. 
  5. No formal determinations for the FBO GSIBs. 
  6. Another one year extension.  
  7. FBO GSIBs will be held to similar standards as their domestic counterparts. 
  8. Extra complications for FBO GSIBs. 
  9. SR 14-1 does apply to FBO GSIBs. 
  10. 15 months is a short window for the FBO GSIBs to meet these standards. 

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Dan Ryan
US Financial Services Advisory Leader
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Armen Meyer
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