Agencies find no deficiencies, shortcomings in ‘living wills’ submitted by 14 big financial firms for 2017

No deficiencies in resolution plans (or “living wills”) for 14 large, domestic banking and financial firms were identified by the Federal Reserve and the Federal Deposit Insurance Corp. (FDIC), the agencies said Friday – unlike those resolution plans submitted in the past.

The two banking agencies said their evaluation of the 2017 living wills revealed no deficiencies or shortcomings, which they described as weaknesses that the firms are required to address, in the plans submitted by:

  • Ally Financial Inc.
  • American Express Company
  • BB&T Corporation
  • Capital One Financial Corporation
  • 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.
  • S. Bancorp.

For 2015, the agencies said, they previously identified three shortcomings in Northern Trust’s living will. However, they stated that the 2017 plan for Northern Trust “satisfactorily addressed these three shortcomings.”

The 2010 Dodd-Frank Wall Street Reform and Consumer Protection Act (Dodd-Frank) requires that firms subject to filing the living wills must describe a firm’s strategy for rapid and orderly resolution under bankruptcy in the event of material financial distress or failure of the firm.

In releasing the living wills for the 14 financial firms, the agencies also noted that they will issue for notice and comment proposed revisions to the living rule, including changes to implement last year’s Economic Growth, Regulatory Relief, and Consumer Protection Act (EGRRCPA, S. 2155).

The agencies said the letters they sent to each of the 14 firms for this year’s evaluations “also outline the expectations under the current rule requirements and explain that, in most cases, the agencies generally expect each firm’s 2019 submission to include only material changes from its previous plan and updated financial statements.”

Agencies complete evaluation of 2017 resolution plans for 14 large domestic banks and issue expectations for 2019 resolution plans

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