FDIC And FRB Propose Updates To Guidance On Resolution Planning

The FDIC and the Federal Reserve Board (collectively, the "agencies") proposed updates to their resolution planning guidance for the eight largest U.S. banks. The proposed guidance would apply to the July 1, 2019 resolution plan submissions by the firms.

The proposed guidance on resolution plans (or "living wills") outlines the preparation required by the Dodd-Frank Act in the event of possible material financial distress or failure. The guidance takes account of the agencies' review of the eight banks in 2017, and would update the expectations for a bank's resolution strategy concerning derivatives and trading activities, as well as payment, clearing and settlement activities. In addition, the proposed guidance "sets expectations for firms regarding their capability to book, monitor, and identify their derivatives exposures, including for exposures that transfer risks between affiliates."