Resolution Plan Deadlines Approaching for Insured Depository Institutions and Holding Companies

The deadline is approaching for depository institutions and holding companies with US$50 billion or more in aggregate assets to submit resolution plans (living wills) to federal banking regulators. Resolution plans for depository institution holding companies having less than US$100 billion in total consolidated assets, are due by year-end 2013, but a notice must be filed by April 1, 2013, if the company wishes to use a simplified "tailored" resolution plan. Nonbank financial companies designated by the Financial Stability Oversight Counsel (FSOC) as being systematically important (SIFIs) will also be required to submit resolution plans, although as of this writing no SIFI designations have yet been issued.

Insured depository institutions with US$50 billion or more in assets, whose parent companies, as of November 30, 2011, had total consolidated assets between US$100 billion and US$250 billion, are required to submit resolution plans by July 1, 2013. Other insured depository institutions with US$50 billion or more in total assets must submit resolution plans by December 31, 2013.