Press Release: Financial Services Forum Outlines Recommendations to Improve Resolution Planning Process

14 Sep 2018

Group Says Updated Regulatory Framework Will Improve Efficiency 


CONTACT: Julia Lawless, (202) 457-8766

WASHINGTON, D.C. –Large U.S. financial institutions have significantly enhanced their resolvability through the resolution planning process, but the current framework should be improved to promote efficiency, the Financial Services Forum said today.

The recommendation came in response to a request for comment from the Board of Governors of the Federal Reserve System (FRB) and the Federal Deposit Insurance Corporation (FDIC) on the resolution planning, or “living wills,” process.

“With nearly a decade of regulatory changes behind us,” Forum CEO Kevin Fromer said, “now is the appropriate time to take stock of the improvements that have been made through implementing the post-crisis framework and to make adjustments that would foster efficiency and transparency and effectively balance the important goals of financial stability and economic growth, innovation, and job creation.”

The Financial Services Forum represents the eight largest, most diversified financial institutions headquartered in the United States. Each Forum member is required to submit to regulators a resolution plan for review.  Each plan is a detailed roadmap of how it would execute a rapid and orderly resolution in the event of material financial distress or failure.

Forum member institutions have significantly enhanced their safety and soundness and improved their capital and liquidity since the post-crisis financial regulatory framework was implemented.  For example, Forum member institutions have more than doubled their high-quality liquid assets since 2010, increased their Tier 1 capital by 40 percent to $900 billion, and simplified their corporate structures to improve transparency and resolvability.

Over the past six years, Forum member institutions have worked directly with the FRB and the FDIC to develop meaningful resolution plans that meet current regulatory standards. Given this experience, they welcome regulators’ decision to solicit public input on how to strengthen and streamline the process.

“Increasing regulatory efficiency will bolster the ability of our member institutions to serve as a leading source of support to the U.S. economy while continuing to protect U.S. financial stability,” Fromer wrote.

Specifically, the Forum recommends the FRB and FDIC:

  • Recognize that the Single Point of Entry strategy is the most effective way to resolve a large financial institution in an orderly manner;
  • Formalize a two-year submission cycle for holding company resolution plans in their regulations;
  • Eliminate the separate requirement for insured depository institution plans;
  • Avoid using the resolution planning process as a means to impose heightened capital and liquidity standards; and
  • Consolidate all applicable resolution planning guidance.

“In light of the progress that has made to strengthen the financial system and the resiliency and resolvability of our member institutions, these adjustments are warranted and appropriate to strike the right balance between financial stability and economic growth,” concluded Fromer.

A copy of the letter can be found here.


 The Financial Services Forum is an economic policy and advocacy organization whose members are the chief executive officers of the eight largest and most diversified financial institutions headquartered in the United States.  Forum member institutions are a leading source of lending and investment in the United States and serve millions of consumers, businesses, investors, and communities throughout the country. The Forum promotes policies that support savings and investment, deep and liquid capital markets, a competitive global marketplace, and a sound financial system.

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Learn More:

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Our institutions support economic growth and a number of steps have led to a more resilient financial sector. Learn more in our briefing slide deck.