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    Home /  Insights /  Memos, Newsletters And Alerts /  Memo
    S&C Memos

    Resolution Planning Guidance for Triennial Full Filers

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    August 8, 2024

    The Federal Reserve and FDIC Finalize Resolution Planning Guidance for Large U.S. and Non-U.S. Banks Known as “Triennial Full Filers”

    The Federal Reserve and the FDIC have issued final joint guidance for Dodd-Frank Act section 165(d) resolution plans filed by large U.S. and non-U.S. banks known as “triennial full filers.” The guidance largely adopts the agencies’ proposed guidance published in September 2023, with targeted modifications and clarifications. The guidance describes the agencies’ supervisory expectations on how a triennial full filer’s resolution plan should address a number of key areas of potential vulnerabilities, depending on whether the filer has chosen a single point of entry (SPOE) or a multiple point of entry (MPOE) strategy. For both domestic and foreign filers, these key areas include capital, liquidity, governance mechanisms, operational capabilities, legal entity rationalization and insured depository institution resolution. For foreign filers, these areas also include the interaction with the filer’s group resolution plan, the continuation of U.S. branches and the separability of U.S. operations. The agencies extended the triennial full filers’ next resolution plan submission deadline from March 31, 2025 to October 1, 2025.

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