Section 165(d) of the Dodd-Frank Wall Street Reform and Consumer Protection Act requires that bank holding companies with total consolidated assets of $50 billion or more and nonbank financial companies designated by the Financial Stability Oversight Council (FSOC) for supervision by the Federal Reserve periodically submit resolution plans to the Federal Reserve and the Federal Deposit Insurance Corporation.

Each plan, commonly known as a living will, must describe the company's strategy for rapid and orderly resolution in the event of material financial distress or failure of the company, and include both public and confidential sections.

Currently, the largest, most complex banking organizations supervised by the Board are required to file resolution plans by July 1 of each year. All other companies supervised by the Board and subject to the resolution planning rule generally are required to file by December 31 of each year.

Board Releases

Guidance for 2019 165(d) Resolution Plan Submissions by Domestic Covered Companies that Submitted Resolution Plans in July 2017 (February 4, 2019)

Bank Holding Company (BHC) Plans and Feedback Letters

Resolution Plans
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Press Releases
December 9, 2020
Agencies announce several resolution plan actions

July 1, 2020
Agencies provide largest firms with information for next resolution plans

May 6, 2020
Agencies extend two resolution plan deadlines

April 27, 2020
Agencies extend comment period on updates to resolution plan guidance for large foreign banks

March 6, 2020
Agencies invite comment on updates to resolution plan guidance for large foreign banks

*Note: The 2019 feedback letter for Goldman Sachs was replaced on February 3, 2020. The previous letter incorrectly included language that has since been removed referencing a project that was not underway at the firm.

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Last Update: December 09, 2020