Fed, deposit insurer put foreign banks on notice for ‘living wills’ by year’s end

Expectations for “living wills” by 19 foreign-owned banks with operations in the U.S. were communicated to the institutions by the Federal Reserve and Federal Deposit Insurace Corp. (FDIC) Monday.

The messages from the regulators told the banks that, for their U.S. operations, the “wills” (known formally as “resolution plans”) are due by Dec. 31.

The most recent plans submitted by the 19 banking organizations were dated December 2015.

The banks put on notice are: Banco Bilbao Vizcaya Argentaria, S.A.; Banco Santander, S.A.; Bank of China Limited; Bank of Montreal; BNP Paribas; BPCE; Coöperatieve Rabobank U.A.; Crédit Agricole S.A.; HSBC Holdings plc; Industrial and Commercial Bank of China Ltd.; Mitsubishi UFJ Financial Group, Inc.; Mizuho Financial Group, Inc.; Royal Bank of Canada; Société Générale; Standard Chartered PLC; Sumitomo Mitsui Financial Group, Inc.; The Bank of Nova Scotia; The Norinchukin Bank; and The Toronto-Dominion Bank.

Resolution plans are required by the Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010 (Dodd-Frank). The plans must describe the company’s strategy for rapid and orderly resolution under bankruptcy in the event of material financial distress or failure of the company.

For foreign banking organizations, resolution plans are focused on their U.S. operations, the Fed and FDIC said.

“To reflect the limited complexity of most of these firms’ U.S. operations, the agencies are further tailoring their expectations for these firms’ 2018 resolution plans,” the agencies said in a joint statement.

Agencies complete assessment of resolution plans of 19 foreign-based banks