Board of Governors of the Federal Reserve System

The Federal Reserve Board and the Federal Deposit Insurance Corporation on Friday provided additional guidance to firms that in December will be filing resolution plans for the second time.  Each plan must describe the company's strategy for rapid and orderly resolution under the U.S. Bankruptcy Code in the event of material financial distress or failure of the company.

One hundred and seventeen U.S. bank holding companies with less than $100 billion in total nonbank assets and foreign-based firms with less than $100 billion in U.S. nonbank assets were required to file their initial resolution plans with the agencies in December 2013. 

Following review of the initial resolution plans, the agencies are providing each firm with guidance, clarification and direction for their second resolution plans based on the relative size and scope of each firm's U.S. operations:

• Thirty-one of the more complex firms are required to file a full resolution plan that takes into account and discusses potential obstacles to resolvability identified by the agencies.  The obstacles include global issues, financial market utility interconnections, and funding and liquidity.  
• Twenty-five firms with less complex U.S. operations are permitted to file tailored plans again this year and can use the model template issued by the agencies or follow the guidelines previously released by the agencies.
• Sixty-one firms with limited U.S. operations may focus their plans on material changes to their initial plans as well as actions taken to strengthen the effectiveness of their initial plans. 

The second plans are due to the agencies on or before December 31, 2014.

Also on Friday, the agencies released the tailored resolution plan template for 2014 plans.  A tailored resolution plan focuses on the nonbanking operations of the firm and on the interconnections and interdependencies between the nonbanking and banking operations. The optional template is intended to facilitate the preparation of tailored resolution plans.

2014 Model Template for §165(d) Tailored Resolution Plan (PDF)