Agencies Simplify 2018 Resolution Plan Requirements for Many Foreign Banks

On January 29, 2018, the Federal Reserve and the FDIC sent feedback letters to 19 foreign banking organizations (“FBOs”) that last filed plans by December 31, 2015.

The most significant take‑away is that the resolution planning requirements for these FBOs have been substantially reduced from those previously required.  Many of the FBOs now are permitted to file reduced or more limited plans by incorporating by reference information from their prior plans and by addressing more streamlined requirements in other areas.  Most significantly, the new feedback did not impose the detailed analytical requirements imposed for the four FBOs with the largest U.S. operations who file their plans by July 1, 2018.  The 19 FBOs must file their next plans by December 31, 2018.