CLS Blue Sky Blog

Cleary Discusses Simplification of 2018 Resolution Plans for Foreign Banks

On January 29, 2018, the Federal Reserve and the FDIC (the “Agencies”) released feedback letters to 19 foreign banking organizations (“FBOs”) that last filed plans by December 31, 2015 (the “FBO Feedback”).[1] The most significant take‑away is that the resolution planning requirements for these FBOs have been substantially reduced from those previously requiredOK. Many of the FBOs now are permitted to file reduced or more limited plans by incorporating by reference information from their prior plans and by addressing more streamlined requirements in other areas. The FBOs must file their next plans by December 31, 2018.

The FBO Feedback grouped the FBOs into two broad categories:

Key Takeaways

Reduced Plans

Limited Plans

  1. Feedback
  1. Contents of Limited Plan

[1]           Federal Reserve and FDIC Joint Press Release, Jan. 29, 2018, available at

This post comes to us from Cleary Gottlieb Steen & Hamilton LLP. It is based on the firm’s blog post, “Agencies Simplify 2018 Resolution Plan Requirements for Many Foreign Banks,” dated February 2, 2018, and available here.

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