On April 13, 2016, the US Federal Reserve Board and Federal Deposit Insurance Corporation jointly determined that the 2015 resolution plans of the following five US domestic global systemically important banking organizations are not credible: Bank of America, Bank of New York Mellon, JP Morgan Chase, State Street and Wells Fargo. The agencies also jointly identified weaknesses in the resolution plans of Goldman Sachs and Morgan Stanley, but did not make joint determinations as to the plans and their deficiencies. Neither agency found that Citigroup’s resolution plan was not credible, although the agencies did identify certain shortcomings that Citigroup must address. Under Section 165(d) of the Dodd-Frank Act, bank holding companies with total consolidated assets of $50 billion or more and nonbank financial companies designated by the FSOC for supervision by the Federal Reserve Board must periodically submit resolution plans to the Federal Reserve Board and the FDIC. The five firms receiving a joint notice of deficiencies must remediate those deficiencies by October 1, 2016, to avoid imposition of more stringent prudential requirements on the firm until it remediates the deficiencies. Such prudential requirements could include more stringent capital, leverage or liquidity requirements, as well as restrictions on growth, activities or operations of the firm, or its subsidiaries.
The agencies are continuing to assess the plans for the four foreign banking organizations that filed resolution plans on July 1, 2015, including Barclays PLC, Credit Suisse Group, Deutsche Bank AG and UBS.
The Federal Reserve Board is releasing the feedback letters issued to each firm. The agencies are also issuing “Resolution Plan Assessment Framework and Firm Determinations (2016),” which provides further information on the determinations and the agencies’ processes for reviewing the plans. Additionally, the agencies are releasing new guidance for the July 2017 submissions for all covered companies. The deadline for the next full plan submission for the eight US GSIBs is July 1, 2017.
The Federal Reserve Board press release, which includes each of the firm feedback letters, 2016 assessment framework and 2017 resolution plan guidance, is available at: http://www.federalreserve.gov/newsevents/press/bcreg/20160413a.htm.