Amy S. Matsuo
National Leader, Regulatory Insights, KPMG US
Key points
The Federal Reserve and the FDIC have proposed to amend their joint rule implementing the resolution planning requirements of the Dodd-Frank Act’s Section 165, Enhanced supervision and prudential standards. The proposed rule would:
Align the approach for applying the resolution planning requirement to the agencies’ proposed enhanced prudential standards frameworks for domestic banking organizations and FBOs, which would tailor requirements based on asset size and risk indicators.
The proposed framework would introduce three types of resolution plan requirements that would correspond to the four categories in the tailoring proposals. The three plan types would vary by filing frequency and required content.
Proposed Framework
Standards Category | Size or Risk Indicators | Content and Frequency | Initial filing dates |
Category I | U.S. GSIBs | Biennial Filer: Resolution plan filed every two years, alternating between a “full” plan and a “targeted” plan. |
July 1, 2019. |
Category II | U.S. firms: ≥ $700b total consolidated assets or ≥ $100b total consolidated assets and ≥ $75b cross-jurisdictional activity FBOs: ≥ $700b combined U.S. assets or ≥ $100b combined U.S. assets and ≥ $75b cross-jurisdictional activity |
Triennial Filer: Resolution plan filed every three years, alternating between a “full” plan and a “targeted” plan. |
July 1, 2021. |
Category III | U.S. firms: ≥ $250b and ≤700b total consolidated assets or ≥ $100b total consolidated assets and ≥ $75b nonbank assets, weighted short-term wholesale funding, or off-balance sheet exposure FBOs: ≥ $250b and ≤ $700b combined U.S. assets or ≥ $100b combined U.S. assets and ≥ $75b nonbank assets, weighted short-term wholesale funding, or off-balance sheet exposure |
Triennial Filer: Resolution plan filed every three years, alternating between a “full” plan and a “targeted” plan. |
July 1, 2021. |
Category IV, Other FBOs | U.S. firms: No filing requirement for firms with ≥ $100b and ≤250b total consolidated assets that do not meet risk indicators thresholds FBOs: Subject to resolution planning, ≥ $250b global consolidated assets, not subject to Category II or Category III |
Triennial Reduced Filers: “Reduced” resolution plan filed every three years. |
July 1, 2022. |
All plan types would include a public section and information regarding actions taken to address any shortcomings or deficiencies identified by the agencies. In addition:
Note: The agencies are proposing to eliminate the current “tailored plan” category.
Notably, the regulators would retain the ability to require a full resolution plan from any firm at any point, including if material changes to a firm occurred during the cycle.
Comments are requested by June 21, 2019.