Foreign Banks: Resolution plans meet IHCs
February 2016
Overview
Foreign banks face great challenges with their US resolution plans this year due to enhanced prudential standards (EPS) and the requirement to establish intermediate holding companies (IHCs).
We believe US regulators expect foreign banks to address their IHCs in this year’s plans, even if the plan is submitted before the July IHC deadline. The plan should include a detailed discussion of the IHC's impact on US operations, and banks should consider whether changes to their resolution strategies are appropriate - e.g., perhaps adopting a Single Point of Entry (SPOE) strategy.
This Regulatory brief analyzes (a) the potential adoption of SPOE, (b) ways to leverage EPS preparation for resolution planning, and (c) other considerations regarding integrating IHCs into resolution plans.
