Yesterday, we assessed the reasons why Wells Fargo failed to meet FRB/FDIC resolution-plan standards (see Client Report LIVINGWILL14); today, we turn to how the rest of the GSIBs that also fell short the last time around (see Client Report LIVINGWILL13) now satisfied these demanding and fractious agencies.  Our review of the regulators’ statements on JPMorgan Chase, BofA, State Street, and BNY Mellon lead us to conclude that successful GSIBs made significant strides in restructuring their operations and internal procedures following their embarrassing and politically-costly rejections in April.  Each of these GSIBs has additional hurdles to cross in its next resolution plan, with much critical detail not made public in the FRBB/FDIC letters.  However, taken together with public reports from these BHCs, it is clear that the resolution-planning process is forcing significant structural change on U.S. GSIBs.

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