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Resolution Authority

Monday, August 18, 2014

Agencies Provide ‘Living Will’ Guidance

The Federal Reserve and FDIC provided guidance to the 117 financial firms filing their second round of resolution plans in December. The guidance comes two weeks after the agencies criticized the second round of “living wills” filed by 11 large, complex banks in 2013.

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.
ABA welcomed the additional guidance and continues to work with regulators to clarify expectations and procedures related to living wills.

Read more.
View the model template.

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