We are posting a presentation on the vulnerabilities, resiliency and resolvability of the U.S. Financial System today compared to 2008.  It is based largely on data from the Federal Reserve’s Financial Stability Report published in November 2019.  This was originally presented by our partner Randall D. Guynn at the Smoketree
Continue Reading An Assessment of Vulnerabilities, Resiliency, Resolvability of the U.S. Financial System, Today vs. 2008

It is back to the future. Federal Reserve Chairman Powell pledged last night to use the “full range of tools” available to support households, businesses and the economy. Today, Davis Polk republishes its 2009 Financial Crisis Manual in the hope that, even though much has changed in the last 11
Continue Reading Republication: The 2009 Davis Polk Financial Crisis Manual

The Federal Reserve has approved its long-awaited Final Rule amending and restating the 165(d) resolution planning rule. The FDIC is expected to soon approve an identical rule.  The Final Rule is largely unchanged from the Federal Reserve’s and FDIC’s May 2019 joint 165(d) Rule Proposal, and among other things:

  • Creates


Continue Reading A New Framework for Resolution Plans

Yesterday, the FDIC issued and invited comments on a proposal to amend and restate their 165(d) Rule, issued jointly with the Federal Reserve, which implements the resolution planning requirements of Section 165(d) of the Dodd-Frank Wall Street Reform and Consumer Protection Act.  This proposal is identical to the version
Continue Reading FDIC Considers Amendments to Resolution Planning Requirements

Today, the Federal Reserve issued and invited comments on a proposal to amend and restate their 165(d) Rule, which implements the resolution planning requirements of Section 165(d) of the Dodd-Frank Wall Street Reform and Consumer Protection Act.

The Notice of Proposed Rulemaking for this new 165(d) Proposal is available
Continue Reading Federal Reserve Proposes Amendments to 165(d) Resolution Plan Rule

The Federal Reserve has finalized a new supervisory ratings system for large financial institutions (LFIs), discussed in our visual memorandum here.  The new LFI rating system, which reflects the three core areas of focus in the Federal Reserve’s current LFI supervisory framework—capital, liquidity and governance and controls—is
Continue Reading Visual Memorandum: The Federal Reserve’s Large Financial Institution Rating System — Final Rule

Today, the Federal Reserve and FDIC released the public sections of the 2018 165(d) resolution plans of Barclays, Credit Suisse, Deutsche Bank and UBS, which were due on July 1, 2018.  The plans contain strategies for the rapid and orderly resolution of each firm’s U.S. operations under the Bankruptcy Code
Continue Reading Release of Public Sections of 2018 IDI Plans and Foreign Filers’ 2018 165(d) Plans

Today, the Federal Reserve and FDIC issued and invited comments on proposed guidance on the 2019 and subsequent submissions of the U.S. G-SIBs’ 165(d) resolution plans. The Proposed Guidance is available here.

The Proposed Guidance is largely similar to the guidance issued by the Agencies in April 2016, with
Continue Reading Federal Reserve and FDIC Issue Proposed Guidance on U.S. G-SIBs’ 2019 Resolution Plan Submissions

On June 19, 2018, Margaret E. Tahyar will moderate the “Supervisory and Examination Issues and Updates” panel at the 2018 Prudential Regulation Conference hosted by SIFMA and The Clearing House in Washington, D.C.  In connection with Ms. Tahyar’s participation in this event, we are today releasing two interrelated visual memoranda
Continue Reading Visual Memoranda: The Federal Reserve’s Proposed Governance Guidance for Boards and Management and Proposed Large Financial Institution Rating System