On March 6, 2020, the Board of Governors of the Federal Reserve
and the Federal Deposit Insurance Corporation proposed for public
comment resolution plan guidance for certain large foreign banking
organizations with significant U.S. operations. 1 The
proposed methodology for determining the applicability of the
guidance would result in only three foreign banking organizations
("FBOs") being subject to the guidance.
2 The Proposed Guidance would apply to the Specified
FBOs' next scheduled July 1, 2021 targeted resolution plan
submissions.
The Proposed Guidance is generally consistent with prior
guidance issued to the Specified FBOs and UBS AG in December 2018,
3 but includes changes to reflect both the 2019
revisions to the resolution planning rule4 and some
aspects of the Agencies' guidance for the 2019 resolution plans
of the eight largest, most complex U.S. banks ("U.S.
G-SIBs"). 5
