The firms due to file in December -- U.S.-based bank holding companies with less than $100 billion in nonbank assets and foreign firms with less than $100 billion in U.S. nonbank assets -- were divided into three groups:
- 31 more complex firms must file full living wills that discuss obstacles to resolution identified by the agencies.
- 25 less complex firms may file tailored plans using the agencies’ new model template.
- 61 firms with a limited U.S. presence may focus their living wills on material changes and improvements to their previously filed plans.
View the model template.