Banking and Finance Law Daily FDIC, Fed extend resolution plan deadlines due to coronavirus impact
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Thursday, May 7, 2020

FDIC, Fed extend resolution plan deadlines due to coronavirus impact

By Charles A. Menke, J.D

The agencies extended two resolution plan deadlines by 90 days as a result of coronavirus related challenges.

The Federal Deposit Insurance Corporation and the Federal Reserve Board have extended two upcoming resolution plan deadlines in light of challenges arising from the coronavirus response, the agencies announced. Resolution plans, more commonly known as living wills, describe a company’s strategy for rapid and orderly resolution in bankruptcy in the event of material financial distress or failure of the company.

The agencies extended the submission date by 90 days, to Sept. 29, 2020, for resolution plans from Barclays, Credit Suisse, Deutsche Bank, and UBS. These plans are required to remediate certain weaknesses—deemed "shortcomings"—previously identified by the agencies. The agencies also extended the submission date by 90 days, to Sept. 29, 2021, for targeted resolution plans from those large foreign and domestic banks in Category II and Category III of the agencies' large bank regulatory framework. The list of 14 domestic and foreign banks required to submit next resolution plans by Sept. 29, 2021, includes: Barclays; Capital One Financial Corporation; Credit Suisse; Deutsche Bank; HSBC Holdings plc; Mizuho Financial Group, Inc.; Mitsubishi UFJ Financial Group, Inc.; Northern Trust Corporation; The PNC Financial Services Group, Inc.; Royal Bank of Canada; The Toronto-Dominion Bank; Truist Financial Corporation; UBS; and U.S. Bancorp.

The agencies added that targeted resolution plans for the eight global systemically important banking organizations will remain due by July 1, 2021, although they intend to monitor conditions and may adjust this deadline if warranted. In July 2019, the agencies announced they had completed evaluations of 2018 resolution plans for 82 foreign banks and 15 domestic banks and extended the deadline for the next resolution plans from these firms in light of an April 2019 proposed rulemaking (see Banking and Finance Law Daily, July 29, 2019).

Companies: Barclays; Capital One Financial Corporation; Credit Suisse; Deutsche Bank; HSBC Holdings plc; Mizuho Financial Group, Inc.; Mitsubishi UFJ Financial Group, Inc.; Northern Trust Corporation; The PNC Financial Services Group, Inc.; Royal Bank of Canada; The Toronto-Dominion Bank; Truist Financial Corporation; UBS; U.S. Bancorp

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