Resolution Planning -- New guidance, more time, no specificity

April 2013
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Resolution Planning -- New guidance, more time, no specificity

At a glance

This Regulatory Brief analyzes the new guidance’s key points, and 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.

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.


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