Shearman & Sterling LLP | FinReg | US <span ><font >Agencies Complete Resolution Plan Evaluation of 16 Domestic Firms and Provide Resolution Plan Guidance to Four Foreign Banks</font ></span >
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  • US Agencies Complete Resolution Plan Evaluation of 16 Domestic Firms and Provide Resolution Plan Guidance to Four Foreign Banks

    03/24/2017
    The US FDIC and the Federal Reserve Board completed their evaluation of the 2015 resolution plans of 16 domestic banks and separately issued guidance to four foreign banks.

    The domestic banks evaluated were: American Express Company, Ally Financial Inc., BB&T Corporation, Capital One Financial Corporation, Comerica Incorporated, Discover Financial Services, Fifth Third Bancorp, Huntington Bancshares Incorporated, KeyCorp, M&T Bank Corporation, Northern Trust Corporation, Regions Financial Corporation, SunTrust Banks, Inc., The PNC Financial Services Group, Inc., U.S. Bancorp and Zions Bancorporation.

    The agencies did not find that any of the resolution plans submitted in December 2015 by these firms were not credible or would not facilitate an orderly resolution under the US Bankruptcy Code. The agencies did, however, identify shortcomings in Northern Trust Corporation’s resolution plan, which must be satisfactorily addressed in the firm’s 2017 plan due by December 31, 2017.

    For the 15 firms without shortcomings, the agencies are tailoring their expectations for the firms’ 2017 resolution plans to reflect the size and complexity of the firms. As a result, the agencies will limit the amount of information the firms are required to submit in their next filings (which are due by December 31, 2017).

    The agencies also issued guidance to four foreign firms -- Barclays PLC, Credit Suisse, Deutsche Bank AG and UBS AG -- to help them improve their resolution plans and to reflect the restructuring that they have undergone to form US intermediate holding companies. The agencies are providing a one-year extension to these foreign firms; their next resolution plans are now due on July 1, 2018.

    The Federal Reserve Board is releasing the extension letters for the foreign firms as well as the individual feedback letters for the domestic firms, which contain firm-specific guidance on areas in need of improvement.

    View the foreign bank guidance.

    View the extension letters for the foreign firms and feedback letters for the domestic firms.