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January 31, 2013

Deadline Approaching for Foreign Banks on Living Wills

Arnold & Porter Advisory

During 2013, foreign banks with US$50 billion or more in global assets, and a branch or agency in the United States, will be required to submit resolution plans (often called "living wills") to U.S. federal banking regulators. Resolution plans of foreign banks with less than US$100 billion in U.S. non-bank assets are due by year-end 2013, but a notice must be filed by April 1, 2013, if the institution wishes to use a simplified "tailored" resolution plan. Resolution plans of foreign banks with between US$100 billion and US$250 billion in U.S. non-bank assets must be submitted by July 2013. Foreign banks with US$250 billion or more in U.S. non-bank assets were required to submit resolution plans in 2012.

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