WASHINGTON Regulators provided more instruction Friday to smaller firms required under the Dodd-Frank Act to simulate their own failures.
In total, about 130 banks with at least $50 billion in assets submit annual "living wills" to the Federal Deposit Insurance Corp. and Federal Reserve Board. The banks are divided into three categories based on complexity with different filing schedules. While the 11 most complex, or "first wave", banks have drawn the most public attention for their plans, the bulk of those required to write wills are in the later waves.
The guidelines released Friday are meant for the 117 "third-wave" banks filing their second drafts in December. Those companies, including U.S. firms with under $100 billion in assets and foreign firms with limited U.S. activities, filed inaugural plans in December 2013.
The agencies said each plan should outline a firms "strategy for rapid and orderly resolution" via the traditional bankruptcy process.
The guidance further divided the 117 institutions into three separate groups, each with different instructions. Thirty-one of the larger organizations must again file a complete resolution plan that addresses possible obstacles to a smooth wind-down. Those obstacles include international issues, problems related to financial market utilities and a potential liquidity shortage.
Twenty-five simpler firms will be allowed to submit plans "tailored" to their business model and can use a model template provided by the agencies. Meanwhile, 61 of the firms that have very limited U.S.-based operations can focus their plans on any "material change" to their earlier drafts and steps the companies have taken to improve the "effectiveness" of their first plans.