10:24 pm - Monday December 18, 2017

DFA and Living Wills (funeral plans)

Section 165(d) of Dodd Frank Act requires each non bank financial company or bank holding company with consolidated assets of $ 50 billion or more to submit periodically a plan for their rapid and orderly resolution in the event of material financial distress or failure.

Plans filed under section 165(d)(1) will assist such banking, financial institutions and regulators in conducting advance resolution planning.

This advance planning has long been a component of resiliency and recovery planning as it improves the efficient resolution.

The final rule requires financial institution to produce a resolution plan, or ‘‘living will,’’ that include information regarding strategic analysis by the institution of how it can be resolved in case of failure or bankruptcy in a way that would not pose systemic risk to the financial system.

The first set of such living wills were filed by select SIFIs to the regulators in US in the last week of June 2012.

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