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Financial Services Law Insights and Observations

Federal Reserve Board Updates Large Institution Supervision Framework

Federal Reserve LISCC

Consumer Finance

On December 17, the Federal Reserve Board (FRB) issued Supervisory Letter SR 12-17, which describes an updated framework for the consolidated supervision of large financial institutions in order to enhance the resilience of a firm, lower the probability of its failure, and reduce the impact on the financial system in the event of an institution’s failure. With regard to the former, the letter specifies the FRB’s expectations with regard to (i) capital and liquidity planning and position, (ii) corporate governance, (iii) recover planning, and (iv) management of core business lines. In support of its goal to reduce the impact of a failed firm, the letter describes the FRB’s  expectations with regard to (i) management of critical operations, (ii) support of banking offices, (iii) resolution planning, and (iv) other macroprudential supervisory approaches. The letter also summarizes the FRB’s supervisory activities designed to assess each firm and support these goals. The framework applies to (i) Large Institution Supervision Coordinating Committee (LISCC) firms, (ii) domestic bank and savings and loan holding companies with consolidated assets of $50 billion or more that are not included in the LISCC portfolio, and (iii) foreign banking organizations with combined assets of U.S. operations of $50 billion or more that are not included in the LISCC portfolio.