Resolution Plan Submission Period Extended by Key Financial Agencies

In discussions with financial services executives, Perficient consultants consistently explore the extension of the submission deadline for resolution plans among certain large financial institutions with assets exceeding $250 billion. Moving forward, these institutions will need to submit their resolution plans by March 31, 2025.

Guidance For Institutions

This guidance applies to institutions with assets exceeding $250 billion, mandated to periodically submit resolution plans to regulatory agencies. The public was invited to comment on the development of their Dodd-Frank Act Title I resolution plans. Known as “Living Wills,” these plans outline a bank holding company’s strategy for prompt resolution in significant financial distress or failure.

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In August 2023, agencies proposed guidance aimed at enhancing resolution plans for large financial institutions with assets surpassing $250 billion, excluding the largest and most complex institutions already following established resolution planning guidance. The focus is on critical areas of potential vulnerability such as capital, liquidity, and operational capabilities, essential for effective resolution.

Looking Forward

Regulatory agencies have indicated considering extending the next resolution plan submission deadline to allow sufficient time for proposed guidance, once finalized, to be incorporated into plan submissions. The public comment period closes on November 30, 2023, and agencies are finalizing the development of the guidance, to be published in the Federal Register.

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