Yearly Archives: 2016

This week, the Federal Reserve and the FDIC (collectively, “Agencies”) released the public sections of the resolution plan progress reports submitted on October 1st by the eight largest US banking institutions (“October Submissions”). [1] In April, the Agencies jointly determined five of the eight banks’ 2015 resolution plans to be “not credible,” while all eight were found to have either “deficiencies,” “shortcomings,” or both. [2] The Agencies identified the deficiencies and shortcomings across six areas, [3] and also issued significant new guidance on these areas for incorporation in the banks’ next full submission. The banks had until October 1st to remediate all deficiencies cited in the April feedback, but were given until their next full resolution plan filing date (which was pushed back by one year to July 1, 2017) to fully address shortcomings. In their October Submissions, the banks were required to include a description of how deficiencies were remediated and the actions taken so far to address shortcomings. Each of the five banks with plans determined to be not credible declared in their October Submission that they believe their deficiencies are now remediated. Time will tell if the Agencies agree.

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