On August 15, 2014, the Board of Governors of the Federal Reserve System (“Federal Reserve Board”) and the Federal Deposit Insurance Corporation (“FDIC”) issued additional guidance following review of the first submission of resolution plans made by 117 US bank holding companies with less than $100 billion in total non-bank assets and foreign-based firms with less than $100 billion in US non-bank assets. The current guidance provides each firm with additional clarification and direction for the second resolution plans based on the relative size and scope of each firm’s US operations. The second plans are required to be submitted to the FDIC and the Federal Reserve Board on or before December 31, 2014.

In conjunction with the guidance, the Federal Reserve Board and the FDIC also released the model template for the tailored resolution plan, which focuses on the non-banking operations of the firm and the interdependencies between non- banking and banking operations.

The full text of the guidance is available at:

http://www.federalreserve.gov/newsevents/press/bcreg/2014bcreg.htm

The full text of the 2014 Model Template for a Tailored Resolution Plan is available at:

http://www.federalreserve.gov/bankinforeg/resolution-plans/2014-model-template.pdf