On June 29, the Federal Reserve and the FDIC proposed for public comment revised resolution plan guidance for the eight largest, most complex U.S. banks.
The proposed guidance would apply beginning with the next scheduled July 1, 2019 resolution plan submissions from the firms. The proposed guidance is largely similar to the guidance issued by the Agencies in April 2016, but provides additional details for inclusion in two areas in upcoming resolution plans: 1) payment, clearing, and settlement activities, and 2) derivatives and trading activities.
Perhaps most significantly, the proposed guidance demonstrates a new emphasis on greater clarity and transparency through notice and comment for the resolution planning process. Both Federal Reserve Vice Chairman for Supervision Randal Quarles and new FDIC Chairman Jelena McWilliams have emphasized the importance of transparency, and Vice Chairman Quarles has specifically commented on the need for public and firm comment on resolution planning guidance.
The proposed guidance identified specific questions for comments and required that all comments be submitted within 60 days from publication in the Federal Register.