General
GEN 1. Sufficiency of Remediation
Q. Can the Agencies confirm that the action steps we have outlined will meet 2018 Guidance expectations?
A. Agency staff cannot confirm whether the actions of the firm are adequate to satisfy the 2018 Guidance. Authority and decision-making relative to resolution plan determinations rest with the respective Boards of the FDIC and Federal Reserve.
GEN 2. Stabilization
Q. What is the required frequency of balance sheets and income statements throughout the stabilization period?
A. Your 2018 Plan must include the actual balance sheet for each Material Entity and the consolidating balance sheet adjustments between Material Entities as of December 31, 2017. Your 2018 Plan also should include pro forma balance sheets for each Material Entity at the beginning and end of the runway period and at key junctures in the execution of the resolution strategy. The pro forma financial statements and accompanying notes in your 2018 Plan should clearly evidence the failure trigger event, the Plan's assumptions, and any transactions that are critical to the execution of the Plan's post-runway strategy, such as recapitalizations, the creation of new legal entities, transfers of assets, and asset sales and unwinds.