On June 8, 2016, the firm published an alert titled “First Wave FBO Filers Not Required to File 2016 Resolution Plans.”
The Federal Reserve and the FDIC today announced that Barclays, Credit Suisse, Deutsche Bank and UBS are not required to file resolution plans in 2016 under the implementing regulations for Section 165(d) of the Dodd-Frank Act. The next resolution plans of these four “First Wave” foreign banking organizations are due on July 1, 2017, rather than July 1, 2016. The Agencies stated that they expect to provide feedback based on the companies’ 2015 plans and additional guidance for their 2017 plans.