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

Financial services regulatory reform will continue to be active in 2020, with developments percolating in all three branches of government.  As we observe the changing landscape, here is the 2020 Vision Edition of our reference tool, which provides context and summarizes current developments across a range of key regulatory areas,
Continue Reading Davis Polk Financial Services Regulatory Reform Tool—2020 Vision Edition

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

Financial services regulatory reform continues to evolve in 2019.  As we observe the changing landscape, here is the Fall Focus Edition of our reference tool, which provides context and summarizes current developments across a range of key regulatory areas, agencies and actors.  We will continue to track these issues and
Continue Reading Davis Polk Financial Services Regulatory Reform Tool—Fall Focus Edition

Financial services regulatory reform continues to evolve in 2019.  As we observe the changing landscape, here is the Summer Spotlight Edition of our reference tool, which provides context and summarizes current developments across a range of key regulatory areas, agencies and actors.  We will continue to track these issues and
Continue Reading Davis Polk Financial Services Regulatory Reform Tool—Summer Spotlight Edition

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 and FDIC (the Agencies) provided feedback on the U.S. resolution plans filed in July 2018 by four Foreign Banking Organizations – finding shortcomings in each, but acknowledging the need for more coordination among U.S. and home country regulators.  Unredacted copies of the letters sent on December
Continue Reading Feedback on Foreign Banks’ July 2018 Resolution Plan Submissions – Key Takeaways

The future of resolution planning for U.S. global systemically important banking organizations (G-SIBs) has started to come into focus.  The FDIC and the Federal Reserve have recently laid out an ambitious agenda designed to put in place Resolution Planning 2.0.  This slide sets forth our collection of the
Continue Reading Resolution 2.0 – The Future of U.S. Resolution Planning for U.S. G-SIBs Starts to Come into Focus

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