Reflecting the far-reaching strategic impact of its actions in 2016 on the resolution plans filed by U.S. GSIBs, the FRB and FDIC have clarified the guidance governing the next living-will rounds. Although the clarifications ostensibly apply only to GSIBs, these BHCs in fact received the answers in the FAQs in 2016. The agencies are releasing them now “to better inform the public” doubtless because of the forthcoming round of franchise-defining resolution plans from large U.S. BHCs and foreign IHCs. The new FAQs are thus of considerable value across the spectrum of filing firms, but the FDIC and FRB nonetheless caution that companies that are not domestic GSIBs should not conclude that compliance with the policy clarified here will be found suitable to their specific circumstances. They also caution that these are staff interpretations that do not bind either the agency or senior officials.
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