On July 28, 2015, the Federal Reserve Board and the FDIC provided guidance to 119 firms that will be filing updated resolution plans in December 2015. These firms include three nonbank financial companies: American International Group, Inc., Prudential Financial, Inc., and General Electric Capital Corporation. Based on a review of the plans submitted in 2014, the agencies have provided direction to each firm with respect to their upcoming resolution plans. The Dodd-Frank Wall Street Reform and Consumer Protection Act requires that bank holding companies with total consolidated assets of $50 billion or more and nonbank financial companies designated by the Financial Stability Oversight Council as systemically important 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 US Bankruptcy Code or other applicable insolvency regime in the event of material financial distress or failure of the company.
The updated plans must be submitted on or before December 31, 2015. Additionally, the agencies released an updated tailored resolution plan template. A tailored resolution plan describes resolution strategies in respect of nonbanking operations of a firm and on the relationship between the nonbanking and banking operations.
The joint press release is available at: http://www.federalreserve.gov/newsevents/press/bcreg/20150728b.htm.
The template for tailored resolution plans is available at: http://www.federalreserve.gov/bankinforeg/resolution-plans/tailoredresolution-model-template.pdf.
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