The FDIC and the Federal Reserve Board (Board) have released the public sections of the recently filed annual resolution plans for 11 firms. Each plan must describe the company's strategy for rapid and orderly resolution in the event of material financial distress or failure of the company.
The Dodd-Frank Act requires that bank holding companies (BHCs) with total consolidated assets of $50 billion or more and nonbank financial companies designated by the Financial Stability Oversight Council (FSOC) submit resolution plans to the FDIC and Board.
In April of this year, the agencies issued guidance regarding information that should be included in the 2013 plans concerning certain obstacles to resolvability under bankruptcy. Those obstacles included funding and liquidity, global cooperation, counterparty actions, multiple competing insolvencies, and operations and interconnectedness.