FDIC And FRB Update Resolution Plan Submission Guidance For Certain Foreign Banks

The FDIC and the Federal Reserve Board (collectively, the "Agencies") finalized previously proposed guidance regarding the submission of the resolution plans with respect to certain large foreign banking organizations ("FBOs").

As previously covered, the proposed guidance was largely consistent with the 2018 FBO guidance and 2019 Domestic Covered Company guidance. The finalized guidance substantially reflects the proposal. However, the Agencies made several modifications to the proposed guidance in response to comments they received, including:

• updating the scope of the guidance to include FBOs that are Category II firms under the tailoring rule (see tailoring rule (see previous coverage);