First Resolution Plans FiledSullivan & Cromwell LLP - July 9, 2012
The first resolution plans – or “living wills” – required under the Dodd-Frank Act have been filed with the FDIC and the Federal Reserve. Nine major U.S. bank holding companies and non-U.S. banks regulated as bank holding companies submitted plans to the Federal Reserve and the FDIC. Each plan includes a publicly available summary, which the FDIC has made available on its website. The publicly available portion of each resolution plan contains only a very small portion of the information contained in the plan, and is not required to contain most of the most sensitive information. The publicly available portions nonetheless may provide some limited insight into the strategies that large banks believe will be useful in ensuring the orderly resolution of a failed systemically significant financial company and ending “too big to fail”.