New U.S. Resolution Plan Guidance and Feedback

On March 24, 2017, the Federal Reserve and the FDIC released guidance for the 2018 resolution plan submissions for Barclays PLC, Credit Suisse Group AG, Deutsche Bank AG, and UBS AG.

No credibility determinations were made on the 2015 plans of these foreign banks. The banks must file their next plans by July 1, 2018.

The new 2018 guidance broadly parallels the guidance provided to the largest U.S.-based banks in April 2016, including requirements for much more granular analyses and steps addressing capital, liquidity, governance playbooks, legal entity rationalization and derivatives and trading activities. However, the 2018 guidance for the foreign banks recognizes differences made necessary by the U.S. IHC requirements and foreign ownership and, significantly, allows these foreign banks to include mechanisms for liquidity support from their foreign parents.

The Federal Reserve and the FDIC also provided individual feedback on the 2015 resolution plans of 16 domestic banks. The domestic banks must file their next plans by December 31, 2017.

However, no guidance, feedback, or due date was provided to other foreign banks that normally file their annual resolution plans in December.