A Non-US Bank's Guide to US Resolution Plans

October 18, 2011

Marking the first major milestone in U.S. regulators’ implementation of systemic risk requirements under the Dodd-Frank Act, the FDIC recently approved two rules setting forth requirements for U.S. resolution planning. One rule, approved jointly with the Federal Reserve Board, requires systemically important financial institutions, including certain non-U.S. banking groups, to prepare resolution plans for their U.S. operations (the “SIFI Rule”). The other rule requires certain large FDIC-insured banks to prepare bank resolution plans (the IDI Rule). As a result, non-U.S. banking groups subject to the SIFI Rule will have to prepare resolution plans for their U.S. operations as a whole and for any FDIC-insured bank subsidiaries subject to the IDI Rule.  The memorandum provides a high-level overview of the rules, with a focus on those aspects most likely to be of interest to the head offices of non-U.S. banking organizations subject to the rules.