Resolution Planning - New guidance, more time, no specificity

April 2013


On April 15, 2013, the Federal Reserve and the FDIC jointly released guidance to the eleven Category 1 financial institutions that submitted resolution plans in 2012 and are required to submit their Version 2.0 plans this year. Although the guidance makes resolution plan preparation more actionable, it also increases supervisory expectations for what constitutes a “credible” plan. Category 2 and Category 3 financial institutions can also glean insight from the guidance into the regulators' priorities for their resolution plans (due this year), paying particular attention to the emphasis on including a concise narrative.

This FS Regulatory Brief (a) analyzes the guidance’s key points, and (b) offers our view that further written regulatory detail is unlikely to be provided in the near term because of the guidance’s link to the Too Big To Fail debate in Washington and because of lack of agreement between the regulators.

Contact us

Dan Ryan
US Banking and Capital Markets Leader
Tel: +1 (646) 471 8488

Alison Gilmore
US Asset and Wealth Management Marketing Leader
Tel: +1 (646) 471 0588