Resolution Planning Checklist: Filing Date Approaches

The Dodd-Frank Act mandates that large banking organizations and certain other firms periodically submit a resolution plan (living will) describing the strategy for resolving the company in a rapid and orderly manner in the event of material distress or failure. The frequency of the resolution plan filing depends on the size and complexity of the organization. To strengthen regulatory oversight of large banking organizations, proposed guidance was issued by the Federal Reserve Board and the Federal Deposit Insurance Corporation in 2023 and the agencies continue to develop the final guidance. As the July 1, 2024, filing deadline approaches for some organizations, companies should review the filing requirements for financial and insured depository institutions.

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Related Content       

• Dodd-Frank Act and Insured Depository Institution Rules Resolution Plans (Living Wills)
  Review this practice note for resolution plan regulatory requirements for financial and insured depository institutions. 

• U.S. Financial Regulatory Structure following the Dodd-Frank Act
  Explore this practice note to gain a comprehensive understanding of the Dodd-Frank Act and key changes that this Act made to the structure of the U.S. financial regulatory framework.

• Dodd-Frank Enhanced Prudential Standards Roadmap
  Access this practice note to gain an understanding of the Federal Reserve and Federal Deposit Insurance Corporation (FDIC) requirements for Living Wills, including addressing nonbanking activities, contractual obligations, and counterparty risks.

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