Agencies’ FBO resolution plan announcements

June 2016


The Federal Reserve and the FDIC (“Agencies”) have not yet released feedback for any of the Foreign Banking Organizations (“FBOs”) that submitted resolution plans in 2015, but they recently made two announcements pertaining to FBO plans going forward. The Agencies provided some relief to Wave 1 FBOs by delaying their next plan submissions by one year, and to Wave 3 FBOs with a limited US presence by reducing expectations for their plans. However, when considered in combination with feedback provided to Wave 1 domestic banks in April 2016, this relief may signal re-prioritization by the Agencies rather than a softening of FBO standards

  1. Regulatory feedback for FBO plans is likely this summer.
  2. The announced one year reprieve for Wave 1 FBOs’ resolution plans means more time to focus on IHCs.
  3. Remediation filings looming for Wave 1 FBOs?
  4. FBOs with limited US operations will be allowed to file “reduced content” resolution plans.
  5. The Agencies can now direct more resources to focus on Wave 3 filers with the greatest US presence.

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