Federal Reserve and FDIC Provide Guidance for Third Wave Filers on 2014 Resolution Plans

On August 15, 2014, the Board of Governors of the Federal Reserve System and the Federal Deposit Insurance Corporation (the “Agencies”) released a Joint Press Release announcing the provision of additional guidance to firms that will be filing resolution plans for the second time in December 2014 (“Third Wave Filers”). Contemporaneously with the Joint Press Release, the Agencies sent letters to each of the Third Wave Filers in which they provided individual guidance based on the relative size and scope of their U.S. operations. The Agencies announcement modifies the requirements imposed on the larger Third Wave Filers in certain specific ways as outlined in their individual guidance letters. Third Wave Filers with more limited U.S. operations, however, have seen a substantial reduction in their regulatory burden with regard to their living-wills.