The Federal Reserve Board and the Federal Deposit Insurance Corporation have granted four foreign banking organizations additional time to submit their next resolution plans.
Previously, the four affected banks—Barclays PLC, Credit Suisse Group, Deutsche Bank AG, and UBS—were required to submit their next plans on July 1, 2016. The agencies, however, determined that the annual resolution plan filing requirement will be satisfied by the submission of 2017 resolution plans, due by July 1 of that year.
The Dodd-Frank Act requires that bank holding companies with total consolidated assets of $50 billion or more or foreign banks with $50 billion or more in global consolidated assets periodically submit resolution plans to the FDIC and the Federal Reserve. Each plan must describe the company's strategy for rapid and orderly resolution under the U.S. Bankruptcy Code or other applicable insolvency regime in the event of material financial distress or failure of the company.
The reason for the extension was cited as recognition of the significant restructuring the banks are undertaking to achieve compliance with the Federal Reserve Board's Intermediate Holding Company requirement, also due on July 1, 2016. The formation of an IHC will codify supervision and regulation of the U.S. operations of a foreign bank, and certain IHC-required initiatives are likely to affect the firms' resolution plans and strategies.
The IHC requirement was established by the Federal Reserve Board in 2014 as part of its implementation of the enhanced prudential standards required under the Dodd-Frank Act for bank holding companies and foreign banking organizations with total consolidated assets of $50 billion or more.
The agencies expect to provide feedback to the four FBOs based on their 2015 plans as well as provide additional guidance to the firms for their 2017 plans.
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