Resolution Plan Assessment Framework and Firm Determinations (2016)
PrintAgencies' Determinations and Required Actions
Bank of America, Bank of New York Mellon, JPMorgan Chase, State Street, Wells Fargo
The agencies have made joint determinations for each of the 2015 plans of Bank of America, Bank of New York Mellon, JP Morgan Chase, State Street, and Wells Fargo. The agencies have issued letters to these five firms detailing the deficiencies in their plans and the actions the firms must take to address them, as required by the Dodd-Frank Wall Street Reform and Consumer Protection Act and the agencies' rule. The specific deficiencies and required remediation for each firm are summarized in appendix A. The nature, rather than the number, of deficiencies identified in a firm's plan reflects the extent of the required remediation.
Each firm must remediate its deficiencies by October 1, 2016, as specified in the letters. The firms must provide a targeted submission addressing their deficiencies by that date. The agencies will review each submission and consider whether the firm has adequately remediated its deficiencies.
With the exception of Wells Fargo, these firms also have shortcomings, which must be addressed by the submission of their July 2017 resolution plans.
Goldman Sachs, Morgan Stanley
The agencies jointly identified weaknesses with regard to the 2015 plans of Goldman Sachs and Morgan Stanley, but did not make joint determinations regarding the plans and their deficiencies. The FDIC found that the plan submitted by Goldman Sachs was not credible or would not facilitate an orderly resolution under the U.S. Bankruptcy Code and identified deficiencies. The Board identified a deficiency in Morgan Stanley's plan and found that the plan was not credible or would not facilitate an orderly resolution under the U.S. Bankruptcy Code. Because the agencies did not make joint findings regarding the plans and their deficiencies, the identified weaknesses constitute shortcomings required to be addressed in their July 2017 resolution plans.
Citigroup
The agencies jointly identified shortcomings, however, neither agency identified deficiencies with regard to Citigroup's 2015 plan. The shortcomings must be addressed in the firm's July 2017 plan.
Expectations for July 1, 2017
All of the firms are required to submit their next full resolution plans by July 1, 2017. In their 2017 plans, firms will be required to address all identified shortcomings, follow all guidance provided by the agencies, and meet the statutory and regulatory requirements for their resolution plans. In meeting these expectations, the actions that firms need to take should be substantially complete by July 2017, as previously communicated by the agencies.
