Judgment on 2015 Domestic First Wave Resolution Plans

On April 13, the Federal Reserve and the FDIC provided feedback on the 2015 resolution plans filed by the eight “First Wave” domestic filers, and issued guidance to govern their 2017 resolution plans.

For the first time, the Agencies jointly determined under their resolution planning rule that resolution plans were “not credible”—making that finding on the 2015 resolution plans of five of the eight First Wave domestic filers.  This Alert provides an analysis of the key takeaways, as well as an overview of the assessment framework, the key themes of the Agencies’ credibility determinations, and the implications for these and other resolution plan filers.