Reflecting a recent GAO report criticizing aspects of the Dodd-Frank living-will process, legislation is advancing to lengthen the filing cycle so that plans could be required only every two years, halting the erratic scheduling that has so far characterized living-will submissions. Greater certainty would result from new requirements that the FRB and FDIC also lay out criteria for approving resolution plans, limiting the extent to which different banks believe they have been held to standards more stringent than those governing like-kind companies, giving planners clearer goals, and providing senior management and directors with the understanding of regulatory expectations essential to informed decision-making.
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