Agencies Finalize New Structure for Resolution Planning: More Focused & Less Frequent

October 18, 2019

The Federal Reserve and the FDIC approved a final resolution planning rule (the “Final Rule”) significantly revising the original rule adopted in 2011. [1]

The Final Rule revamps the 2011 requirements by aligning the timing and certain requirements for resolution planning with the filer’s categorization under the Federal Reserve’s October 10th final tailoring rule. Most significantly, the Final Rule allows all filers to submit more targeted or reduced resolution plans, rather than full plans, in their next submission, generally streamlines content requirements for many filers, and creates new waiver and related procedures that could permit further tailoring of requirements based on the potential systemic significance of different filers.  The Final Rule largely adopts the April proposal, but provides important clarifications and procedural improvements.

To read the full alert memorandum, click here.