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Thousands of pages will soon arrive in Washington in the first round of living wills for systemically important firms. Many observers say these initial drafts could shape future standards and determine the wills' effectiveness in ending "too big to fail."
June 25 -
While the living will rule requires firms to provide voluminous data on many aspects of their banking companies, regulators are likely to be primarily focused on a narrative of how they can be taken apart.
December 5 -
"It is about saving the financial economy, not saving a firm," says Jim Wigand, the 28-year FDIC veteran tasked by Congress with ending Too-Big-to-Fail bailouts.
May 16
WASHINGTON — A senior official at the Federal Deposit Insurance Corp. this week called the initial phase of large firms preparing wind-down plans "a positive first step."
Jim Wigand, who runs the FDIC's new Office of Complex Financial Institutions, said the early submitters "did take this exercise very seriously."
"We received large amounts of information that can probably be improved on in the second round. But that being said, the robustness of the exercise clearly was evident in their submissions," Wigand said in informal remarks late Tuesday at a Women in Housing and Finance meeting. "From that perspective, I think, we can take that as a positive first step. But that's what it is: a first step."
Under Dodd-Frank Act rules meant to make failures more manageable, 11 of the largest firms have given the FDIC and Reserve Board the first iterations of their so-called living wills. These resolution plans will be updated through future drafts, and subsequent groups will deliver first drafts later this year. The wills are intended partly to assist the planning of a new FDIC facility for resolving systemically risky firms.
The long reports include minute details about company structure and wind-down strategies. Although regulators have cited a definite learning curve in the development and handling of the wills, especially for the first drafts, they are authorized to force structural changes if a company's report is ultimately deemed subpar.
"This is a learning process for the companies, and this is a learning process for the regulators who have to review the plans," Wigand said.
He said regulators have finished an "informational completeness review" of the initial drafts, and have moved on to what he called a "credibility review." The regulators are not only evaluating each institution for the quality of information, he noted, but also using this early step to form expectations for later submissions.
The regulators are "looking at how this first set of submissions should inform us on guidance we provide for the second round of submissions by the first set of submitters, as well as the companies that will submit for the first time in July of this year, and those that submit for the first time at the end of the year," Wigand said.
