Summary:
This FIL supplements FIL 34-2024 regarding Final Rulemaking on Resolution Plans Required for Insured Depository Institutions with $100 Billion or More in Total Assets; Informational Filings Required for Insured Depository Institutions with At Least $50 Billion but Less Than $100 Billion in Total Assets (final rule) issued on June 20, 2024. This final rule was published in the Federal Register on July 9, 2024. The effective date of the rule is October 1, 2024, and initial submission dates have been communicated to covered insured depository institutions (CIDIs).
Statement of Applicability: Insured depository institutions with $50 billion or more in total assets.
Highlights:
On June 20, 2024, as described in FIL 34-2024 issued that day, the FDIC Board of Directors approved a final rule to strengthen resolution planning for CIDIs with at least $50 billion in total assets. The final rule describes requirements for two groups of CIDIs: group A CIDIs, which are CIDIs with $100 billion or more in total assets, and group B CIDIs, which are CIDIs with at least $50 billion but less than $100 billion in total assets. The FDIC subsequently communicated to each CIDI the anticipated date of its initial submission under the final rule.
The frequency of full resolution submissions under the final rule for most CIDIs is three years; these triennial filers will submit limited interim supplements for a specified subset of submission content items in the off years. The frequency of full resolution submissions for CIDIs that are affiliates of U.S. global systemically important banking organizations (U.S. G-SIB) is two years. These biennial filers are not required to submit an interim supplement in years when the U.S. G-SIB parent of the CIDI files a resolution plan under Title I of the Dodd-Frank Act (Title I plan).
The initial submission date recently communicated to each CIDI is set forth below. Group A triennial filers that are not filing a resolution plan as their initial submission will file an interim supplement first.
Group A Cohort 1: Initial 360.10 Resolution Plan due on or before July 1, 2025
- Citizens Bank, N.A.
- Charles Schwab Bank SSB
- First-Citizens Bank & Trust Co.
- Fifth Third Bank, N.A.
- Flagstar Bank, N.A.
- Huntington N.B.
- KeyBank, N.A.
- Manufacturers & Traders Trust Co.
- Regions Bank
- Santander Bank, N.A.
- Synchrony Bank
- USAA Federal Savings Bank
Group A Cohort 2: Initial 360.10 Resolution Plan due on or before July 1, 2026; Initial Interim Supplement due on or before July 1, 2025
- Ally Bank
- American Express N.B.
- BMO Bank, N.A.
- Capital One, N.A.
- Discover Bank
- HSBC Bank USA, N.A.
- The Northern Trust Company
- PNC Bank, N.A.
- TD Bank, N.A.
- Truist Bank
- UBS Bank USA
- US Bank, N.A.
Group A Cohort 3: Initial 360.10 Resolution Plan due on or before July 1, 2026 (no Interim Supplement due in 2025 if Title I Plan submitted in that year, as expected)
- Bank of America, N.A.
- The Bank of New York Mellon
- Citibank, N.A.
- Goldman Sachs Bank USA
- JPMorgan Chase Bank, N.A.
- Morgan Stanley Bank, N.A.
- Morgan Stanley Private Bank, N.A.
- State Street Bank & Trust Co.
- Wells Fargo Bank, N.A.
Group B Cohort 1: Initial 360.10 Informational Filing due on or before October 1, 2025
- CIBC Bank USA
- City National Bank
- Comerica Bank
- East West Bank
- Valley National Bank
- Zions Bancorporation N.A.
Group B Cohort 2: Initial 360.10 Informational Filing due on or before April 1, 2026
- Banco Popular de Puerto Rico
- First Horizon Bank
- Synovus Bank
- Umpqua Bank
- Webster Bank
- Western Alliance Bank