On December 20, 2018, the Federal Reserve and the FDIC finalized revised resolution plan guidance for the eight largest, most complex U.S. banks.
The final guidance applies beginning with their July 1, 2019, resolution plan submissions. This guidance is largely similar to the proposed guidance published for comment by the Agencies in June 2018, though the Agencies responded to the six comment letters received by clarifying certain issues. The final guidance principally provides updates to prior guidance, including 2016 guidance to the U.S. G-SIBs, in two substantive areas: 1) payment, clearing and settlement activities and 2) derivatives and trading activities. While the proposed guidance sought comment on additional areas relevant to resolution planning, in particular capital and liquidity, the final version of the guidance does not materially change prior guidance in those other areas. Most significantly, the guidance consolidates all prior resolution planning guidance and expressly supersedes any prior guidance not incorporated in or appended to the final guidance.