Agencies Propose Revised RRP Rules

On April 8, 2019, the Federal Reserve proposed a broad overhaul of the 2011 regulations governing resolution planning, which would significantly reduce the frequency of submissions and simplify requirements for many resolution plans.

The Proposal would modify the existing rule to incorporate the experience gained since the first plans were filed in 2013 to target planning efforts on key resolvability issues, while codifying the focus on the eight U.S. global systemically important banks.  Most significantly, the U.S. G-SIBs would only file resolution plans every two years alternating between full resolution plans and more limited “targeted plans”.  All other filers, including the four foreign banking organizations with the largest, most complex U.S. operations  would file resolution plans only every three years, similarly alternating between full and “targeted plans”.  U.S. filers with total consolidated assets below $250 billion would not be required to file any resolution plan.

This article was republished by The Columbia Law School Blue Sky Blog.