regulatory, resolution planning guidance

Perspectives

Resolution planning guidance for financial institutions

Perspectives on the FRB’s and FDIC’s guidance

Bank holding companies with total consolidated assets of $50 billion or more and nonbank financial companies designated by the Financial Stability Oversight Council (FSOC) for supervision by the Federal Reserve periodically submit resolution plans to the Federal Reserve and Federal Deposit Insurance Corporation (FDIC). This page provides Deloitte’s perspective and analysis of the periodic guidance, providing key takeaways and insights for financial firms.

Agencies expecting coronavirus response outcomes and lessons learned to be covered in next round of resolution plans | July 2020

On July 1, 2020, the Federal Reserve Bank (FRB) and Federal Deposit Insurance Corporation (FDIC), together referred to as the "agencies," released a joint statement (Statement) informing the eight largest domestic banking organizations (the US Bank Holding Companies that are US globally systemically important institutions) that their next resolution plan submission will need to include additional information that will provide the agencies with a better understanding of how their resolution planning capabilities fared in response to the coronavirus. This new "Targeted Information Request" will be added as part of their next resolution plan submission that is scheduled for July 1, 2021 (2021 Submission).

The new request expands on the expected information required in the targeted response to also capture linkages between lessons learned across the coronavirus response and resolution activities that were incorporated into the resolution planning process. Prior to the agencies’ Statement, the 2021 Submission had been expected to be the banks’ first iteration of a ‘Targeted’ resolution plan, which is a lighter version than a ‘Full’ resolution plan. The eight largest domestic banks alternate their bi-annual resolution plan submissions between ‘Targeted’ and ‘Full’ plan submissions.

Our latest article provides key takeaways from the guidance and steps financial firms can take to start preparing.

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