The FDIC and FRB – which share authority in this area – are proposing significant changes to their resolution-planning rules following changes to EGRRCPA and their own conclusions about beneficial revisions. The most important of these would change living-will filings as detailed below to make complete filings less frequent, alleviating burden and reflecting delays between plan submission and regulatory feedback which have made it difficult for BHCs to anticipate concerns as they undertake planning while awaiting guidance. The agencies also believe that covered companies have significantly improved their resolvability, making unnecessary the current schedule.
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