Agencies resolution plans actions announced

A joint press release from the Federal Reserve Board and FDIC has announced several resolution plan actions. Resolution plans, commonly known as living wills, must describe a financial company's strategy for rapid and orderly resolution in bankruptcy in the event of material financial distress or failure of the company.

First, the agencies confirmed that weaknesses previously identified in the resolution plans for several large foreign banks—Barclays, Credit Suisse, Deutsche Bank, and UBS—have been remediated.

Second, the agencies finalized guidance for the resolution plans of certain large foreign banks. The final guidance modifies the proposed guidance, which was issued in March of this year, in several ways. The agencies tailored their expectations around resolution capital and liquidity, derivatives and trading activity, as well as payment, clearing, and settlement activities. The scope of the guidance was also modified to generally cover foreign banks in category II of the agencies' large bank regulatory framework. As a result, the guidance will apply to the 2021 resolution plans from Barclays, Credit Suisse, and Deutsche Bank, and also to MUFG (Mitsubishi UFJ Financial Group) for its full plan due in 2024.

And third, the agencies provided information for large foreign and domestic banks that will inform the content of their next resolution plans, which now are due December 17, 2021. In particular, these targeted plans will be required to include core elements of a firm's resolution strategy—such as capital, liquidity, and recapitalization strategies—as well as how each firm has integrated changes to and lessons learned from its response to the coronavirus into its resolution planning process. The information applies to foreign and domestic banks in categories II and III of the large bank regulatory framework.

• Federal Register notice: Guidance for Resolution Plan Submissions of Certain Foreign-Based Covered Companies
• List of 15 Domestic and Foreign Banks Required to Submit Next Resolution Plans by December 17, 2021