On August 2, 2016, the Federal Reserve and FDIC announced that 38 firms will be required to submit their next resolution plans by December 31, 2017, extending the existing deadline by one year. The Agencies also announced that they would provide feedback and guidance based on the firms’ 2015 plans, which is widely expected to be received before end of year to allow firms sufficient time to prepare for their 2017 submission.
December filers would be well advised to begin revising their overall resolution program structure, as well as preparing for the requirements likely to be imposed upon them, by identifying potential areas where enhancements could be required.
In doing so, firms can leverage the guidance Agencies already provided for the eight U.S. domestic G-SIB filers earlier this year, and can seek to learn from the experiences of those institutions in complying with the enhanced expectations outlined there.
