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Resolution Authority

Wednesday, August 3, 2016

Fed, FDIC Delay Deadline for Most ‘Living Wills’ to 2017

The Federal Reserve and FDIC have announced that they are delaying the deadline to file resolution plans, or “living wills,” from Dec. 31, 2016, to Dec. 31, 2017, for 36 large banking organizations and two systemically important nonbanks. Meanwhile, the agencies said they will provide feedback on the 2015 round of resolution plans in time for the 2017 filing.

The delay does not apply to the eight U.S. institutions designated as “global systemically important banks”: Bank of America, Bank of New York Mellon, Citigroup, Goldman Sachs, J.P. Morgan Chase, Morgan Stanley, State Street and Wells Fargo.

The resolution plan process – which applies to U.S. bank holding companies with assets of more than $50 billion, nonbanks designated as systemically important by the Financial Stability Oversight Council and large foreign banks with U.S. operations – requires these large institutions to describe their strategy for a rapid and orderly wind-down in the event of stress. Planning requirements are tiered based on a firm’s level of complexity.

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