The release last week of public summaries of the resolution plans submitted by the 12 largest financial institutions operating in the US reveal more insight into the institutions' resolution strategies than ever before. There is a notable shift toward a Title I single point of entry ("SPOE") strategy among domestic institutions.
2015 is an important year for resolution planning, as the regulators made it clear in guidance issued last August that the major financial institutions will need to be able to demonstrate more convincingly that they can be resolved without significantly impacting US financial stability - i.e., that they are not "Too Big To Fail."
Being public summaries, the disclosures do not include substantial sensitive, proprietary details to demonstrate how feasible or executable the strategies are today. Nevertheless, these summaries present the greatest transparency to the public of any major financial institution's resolution plan in any market globally.
This Regulatory brief provides (a) key background information, (b) an analysis of the disclosed resolution strategies and other important enhanced disclosures, and (c) our view of what happens next.