United States: FDIC And FRB Propose Updating Resolution Plan Submission Guidance For Certain Foreign Banks

The FDIC and the FRB proposed updating the resolution plan submission guidance for certain large foreign banking organizations ("FBOs").

According to the agencies, the proposal is largely consistent with the 2018 FBO guidance and 2019 domestic Covered Company guidance. Specifically, the proposal would:

• update the payment, clearing and settlement, and derivatives and trading activities areas of the 2018 FBO guidance to address the agencies' review of the 2018 resolution plans of certain Specified FBOs and revisions to the 2019 domestic guidance;
• include minor clarifications to the 2018 FBO guidance to reflect the 2019 revisions;
• clarify and streamline the submission process; and
• consolidate all guidance applicable to the Specified FBOs.

Additionally, the agencies noted that the proposed guidance is not intended to limit a firm's assessment of additional vulnerabilities or obstacles unique to its particular structure, operations or resolution strategy.

Comments should be received by May 5, 2020.

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