Fed, FDIC release regional banks’ living will plans

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WASHINGTON — The Federal Reserve and Federal Deposit Insurance Corp. on Monday released the public portions of resolution plans, also known as "living wills," for 16 regional banks and one foreign banking organization with assets of $50 billion to $100 billion.

Banks with more than $50 billion of assets are considered systemically important financial institutions under the Dodd-Frank Act and must have their living wills approved, among other requirements. The Fed and FDIC jointly approve bank resolution plans.

Regulators had approved all of the regional banks’ most recent 2015 resolution plan submissions in March, with the exception of Northern Trust, whose plan was found to have a handful of shortcomings requiring attention in the 2017 submission. Those issues were related to the bank’s unique multiple-point-of-entry resolution structure; under such a resolution, regulators would take over not only the holding company, but also important affiliates in the event of a bank failure.

Northern Trust said in its public submission that it had addressed the failings the regulators identified in March. With respect to liquidity concerns, the bank said that its revised resolution plan “conservatively assumes adverse ring-fencing actions by foreign authorities and that liquidity in foreign jurisdictions remains trapped throughout the resolution scenario,” and those revised assumptions “recalibrate certain liquidity metrics and establish resolution triggers.”

Northern Trust also “enhanced its analysis” under the FDIC’s “least cost test and other applicable requirements,” ensuring that there are minimal conflicts between creditors across jurisdictions and that in the event of resolution, “all U.S. depositors, foreign depositors and other general unsecured creditors are expected to be paid in full.” The bank also revised important third-party service contracts to ensure that resolution would not disrupt services for bank customers.

In addition to Northern Trust, the banks which had their living wills released were: Ally, American Express FSB, BB&T, Capital One, Comerica, Discover FSB, Fifth Third Bancorp, Huntington Bancshares, KeyCorp, M&T, PNC, Regions, SunTrust, U.S. Bancorp and Zions Bancorp.

The Fed also released a resolution plan for one foreign banking organization, E.Sun FSB, which is headquartered in China. All 17 resolution plans were due to the Fed and FDIC by Dec. 31.

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Living wills Dodd-Frank Northern Trust Federal Reserve FDIC