Feedback letters from 15 banking organizations with more than $250 billion in assets on their resolution plans were published Sept. 29 by the Federal Reserve and the Federal Deposit Insurance Corp. (FDIC), the agencies said.
However, the Office of the Comptroller of the Currency (OCC) voted against releasing one of those letters. And, another letter, the agencies said, overturned a “shortcoming” identified five years ago by one bank. None of the other 14 letters either changed past, identified shortcomings or identified any new deficiencies.
The agencies said the resolution plans (also known as “living wills”) were based on a joint review of the 2025 resolution plan submissions from the 15 banking organizations. Those firms were:
- American Express Co.
- Bank of America Corp.
- Bank of New York Mellon Corp.
- Barclays PLC
- BNP Paribas
- Citigroup Inc.
- Deutsche Bank AG
- The Goldman Sachs Group
- HSBC North America Holdings, Inc.
- JPMorgan Chase & Co.
- Morgan Stanley
- State Street Corp.
- UBS Group AG
- Wells Fargo & Co.
The agencies said the shortcoming of BNP Paribas previously identified in its 2021 resolution plan “has been satisfactorily addressed.” No other details were provided.
Meanwhile, Comptroller Jonathon Gould released a statement outlining his opposition to releasing the letter addressed to American Express Co. Gould said reforms were needed in the resolution planning process.
“We have gone too far in forcing banks to structure themselves to fail in an effort to excuse our own inability to resolve them; banks should be built to serve the lending and other financial needs of their communities and customers,” Gould stated. “Even raising the specter of large-scale restructuring based on this high-level, non-‘shortcoming’/non-deficiency feedback is unacceptable.”
Agencies Publish Resolution Plan Feedback Letters for 15 Banking Organizations
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