Title

A New Framework for Resolution Plans
Client Memorandum

Created date

10/14/2019

The Federal Reserve has approved its long-awaited Final Rule amending and restating the 165(d) resolution planning rule. The FDIC is expected to soon approve an identical rule. The Final Rule is largely unchanged from the Federal Reserve's and FDIC's May 2019 joint 165(d) Rule Proposal, and among other things:

  • Creates three types of submissions (full, targeted, and reduced plans); and
  • Applies content, submission cycle, and other requirements to firms based on their category in the Domestic and FBO Tailoring Rules and for certain FBOs, based on their global consolidated assets.

Click below for a visual memo that provides key takeaways and deeper dives.