Resolution Plans under the Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010. AIBA Second Annual Compliance Seminar – June 14, 2012. Charles Gray, Counsel and Assistant Vice President Federal Reserve Bank of New York.
AIBA Second Annual Compliance Seminar – June 14, 2012
Charles Gray, Counsel and Assistant Vice President
Federal Reserve Bank of New York
The views expressed are the views of the author and do not necessarily reflect the views of the Federal Reserve Bank of New York, or any component of the Federal Reserve System.
April 22, 2011
November 1, 2011, and went into effect on November 30, 2011
U.S. Focus. A foreign-based covered company’s plan should be focused on subsidiaries, branches, agencies and operations that are domiciled or conducted in whole or in material part in the U.S. (though analysis of interconnections and interdependencies with foreign-based affiliates is required).
Group-Level Planning. Plan should explain how resolution planning for U.S. entities, critical operations and core business lines is integrated into foreign-based covered company’s overall (home-country) resolution or other contingency planning process.
Non-U.S. Requirements. Many covered companies, both U.S. and foreign-based, are also subject to non-U.S. resolution planning requirements.
Tailored Plan Option. Available to non-U.S. covered firms with less than $100 billion in total U.S. nonbank assets and whose U.S. IDI, branch and agency operations constitute less than 85 percent of such company’s U.S. total consolidated assets.