FDIC Publishes Resolution Plans for Systemically Important Financial Institutions

As required by Parts 360.10 and 381.8(c) of Title 12 of the Code of Federal Regulations, the resolution plan of every insured depository institution with USD 50 billion or more in total assets and every systemically important financial institution is required to split into a public section and a private section.  The Federal Deposit Insurance Corporation has published the public sections of the resolution plans for the following institutions on its website:

  • Bank of America Corporation
  • Barclays PLC
  • Citigroup Inc
  • Credit Suisse Group AG
  • Deutsche Bank AG
  • The Goldman Sachs Group Inc
  • JP Morgan Chase and Co
  • Morgan Stanley
  • UBS AG

However, those hoping to discover any real insights into the resolvability of these institutions will be disappointed.  Understandably, the public sections of each resolution plan reveal no commercially sensitive information.   Rather, they take the form of a standard summary which provides the following high-level information: 

  • The names of material entities;
  • A description of core business lines;
  • Consolidated or segment financial information regarding assets, liabilities, capital and major funding sources;
  • A description of derivative activities and hedging activities;
  • A list of memberships in material payment, clearing and settlement systems;
  • A description of foreign operations;
  • The identities of material supervisory authorities;
  • The identities of the principal officers;
  • A description of the corporate governance structure and processes related to resolution planning;
  • A description of material management information systems; and
  • A description, at a high level, of the covered company’s resolution strategy, covering such items as the range of potential purchasers of the covered company, its material entities and core business lines.

 

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