Prudential Standards and Living Wills: Section 165 of the Dodd-Frank Act - Will It Really Mitigate Risk?
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The historic Dodd-Frank Wall Street Reform and Consumer Protection Act enacted in July 2010 dramatically changed the regulatory landscape for financial institutions. Section 165 of Dodd-Frank is a key part of the legislation's aim at shoring up supervision of large banking and non-bank financial institutions by U.S. regulators. The last of the banking institutions to be required to file their resolution plans under Section 165 will do so by the end of this year. The FRB is reviewing hundreds of comments on the proposed prudential standards it is required by Dodd-Frank to impose on both U.S. banks and non-U.S. banks doing business in the United States. Among the issues we will discuss are:
• What are the ramifications of the proposed prudential standards for U.S. banks and the domestic U.S. banking industry?
• How do the proposed prudential standards for non-U.S. banks differ from those for U.S. banks and will their imposition cause some non-U.S. banks to pack up and go home?
• What should banks required to file their first resolution plans by December 31 be doing now to prepare?
• What exactly does a living will look like - how long, how detailed, how public?