As part of the Dodd-Frank Act financial reforms, large financial institutions were required to submit to U.S. regulators so called “living wills,” outlining the ways in which each large financial institution would wind down its operations should it find itself in catastrophic financial distress. Under the Dodd-Frank Act, should regulators find a bank’s submitted plan not credible, they could force the financial institution to restructure its operations, or even sell off certain business lines. According to experts, it is doubtful that regulators will use the plans to force major structural changes. Regulators have only released small summary memorandums of each “living will” as the banks submitted their detailed plans to regulators confidentially. According to reports, nine of the largest global banks released plans saying that they could be salvaged or dismantled without taxpayer bailouts should they become insolvent. Regulators plan to respond to the proposed “living wills” by September of this year. (“Top banks say they are not too big to fail,” Reuters, July 3, 2012).
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Regulators release portions of big banks’ living wills
- Sedgwick LLP
- USA
- July 31 2012
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Audrey E Mross
Labor & Employment Attorney
Munck Carter LLP