Banking Agencies Permit "Reduced Content" Living Wills For Smaller FBOs

O
Orrick

Contributor

Orrick logo
Orrick is a global law firm focused on serving the technology & innovation, energy & infrastructure and finance sectors. Founded over 150 years ago, Orrick has offices in 25+ markets worldwide. Financial Times selected Orrick as the Most Innovative Law Firm in North America for three years in a row.
To file reduced content plans for the next three years, the firms must maintain less than $50 billion in U.S. assets and not experience any material events.
United States Finance and Banking

On June 10, 2016, the Federal Reserve Board and Federal Deposit Insurance Corporation announced they are permitting 84 foreign banking organizations (not identified) with limited U.S. operations to file “reduced content” resolution plans for their next three resolution plans. As reported, the decision is intended "to increase clarity and reduce burden by creating more certainty around future filing requirements." All of the 84 firms have less than $50 billion in total U.S. assets. The agencies said "the reduced content plans should focus on changes the firms have made to their prior resolution plans, actions taken to improve the effectiveness of, or that may alter, those plans, and, where applicable, actions to ensure any subsidiary insured depository institution is adequately protected from the risks arising from the activities of nonbank subsidiaries of the firm. The first of these reduced content plans must be submitted to the agencies by December 31, 2016. To file reduced content plans for the next three years, the firms must maintain less than $50 billion in U.S. assets and not experience any material events.

The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.

Mondaq uses cookies on this website. By using our website you agree to our use of cookies as set out in our Privacy Policy.

Learn More