The Dodd-Frank Act requires large banking organizations and certain other firms to 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, as well as include both public and confidential sections. Companies covered by the resolution plan rule are categorized according to size and complexity. The frequency of and the informational content requirements for resolution plan submissions are tailored according to firm category.
Currently, the largest, most complex banking organizations are required to file a resolution plan every other year. Other large domestic and foreign banking organizations are required to file a resolution plan every three years. A third group of firms are required to submit abbreviated resolution plans every three years.
Bank Holding Company (BHC) Plans and Feedback Letters
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