‘Living wills’ for more than 700 FIs published, dating back to 2012

Unedited “living wills” for 738 financial companies – including bank holding companies with $50 billion or more than in assets and nonbank financial companies designated for supervision – dating from to 2012 to the last day of 2018 have been published by federal regulators.

The wills – published by the Federal Deposit Insurance Corp. (FDIC) and known more formally as resolution plans – are required under the 2010 Dodd-Frank Wall Street Reform and Consumer Protection Act. Each must describe the company’s strategy for “rapid and orderly resolution under the U.S. Bankruptcy Code in the event of material financial distress or failure of the company.”

With both public and confidential sections included, the plans are required for bank holding companies (BHCs) with total assets of $50 billion or more and nonbank financial firms designated by the Financial Stability Oversight Council (FSOC) for supervision by the Federal Reserve. Those two groups of firms must periodically submit their plans to the Fed and the FDIC.

The list of livings wills is sortable by date submitted, bank/firm name, type of plan and more. The earliest plan dates to July 2, 2012 (for Bank of America Corp.).

In a release, the FDIC said that the plans it publishes on its website include the public sections. Those have not been edited or reviewed by the agency and are provided “exactly as submitted by the companies.”

Firms that are required to file the plans do so on a staggered basis, the FDIC noted; the largest BHCs (domestic companies with $100 billion or more in nonbank assets and foreign-based companies with $100 billion or more in U.S. nonbank assets) and FSOC-designated firms do so on or before July 1. All other firms generally are required to submit their plans on or before Dec. 31 each year, the agency said.

Last fall, FDIC Chairman Jelena McWilliams said that her agency would pursue a “Trust through Transparency” initiative, designed to provide “new performance metrics that cross its business lines.” The metrics, McWilliams said last year, would include data on the turnaround times for examinations and bank applications and timely response rates for the FDIC call center, among other things.

Title I and IDI Resolution Plans

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