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Financial Services Law Insights and Observations

Agencies extend two resolution plan filing deadlines

Federal Issues Agency Rule-Making & Guidance Covid-19 Living Wills Of Interest to Non-US Persons

Agency Rule-Making & Guidance

On May 6, the FDIC and Federal Reserve extended the following two upcoming resolution plan filing deadlines for certain banks in light of recent challenges arising from Covid-19:

  • September 29, 2020 (90 day extension). This extension applies to the four institutions required to submit plans to address previously identified shortcomings.
  • September 29, 2021 (90 day extension). This extension applies to the targeted resolution plans to be submitted by large foreign and domestic Category II and Category III banks under the agencies’ large bank regulatory framework.

Resolution plans for the eight global systemically important banks are still due July 1, 2021, however the agencies noted that they “will monitor conditions and may adjust this deadline if warranted.”