Cleary Gottlieb Discusses Fed’s Proposed Resolution-Planning Rules Overhaul

On April 8, 2019, the Federal Reserve proposed a broad overhaul of the 2011 regulations governing resolution planning (the “Proposal”)[1], which would significantly reduce the frequency of submissions and simplify requirements for many resolution plans.  The Proposal would modify the existing rule to incorporate the experience gained since the first plans were filed in 2013 to target planning efforts on key resolvability issues, while codifying the focus on the eight U.S. global systemically important banks (“U.S. G‑SIBs”).  Most significantly, the U.S. G-SIBs would only file resolution plans every two years alternating between full resolution … Read more