FEDERAL RESERVE AND FDIC PROPOSE NEW RULES REGARDING PREPARATION OF LIVING WILLS

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1 CLIENT MEMORANDUM FEDERAL RESERVE AND FDIC PROPOSE NEW RULES REGARDING PREPARATION OF LIVING WILLS On March 29, 2011, the Board of Governors of the Federal Reserve System (the Federal Reserve ) and the Federal Deposit Insurance Corporation (the FDIC and, together with the Federal Reserve, the Agencies ) released proposed rules to implement 165(d) of the Dodd- Frank Act. Under the Notice of Proposed Rulemaking (the NPR ), each covered company 1 is required (1) to submit a resolution plan, or living will, providing for the rapid and orderly resolution 2 of the company under Title 11 of the United States Code (the Bankruptcy Code ) in the event it experiences material financial distress and (2) to file credit exposure reports that describe the credit exposure the Covered Company has to other significant nonbank financial companies and bank holding companies and vice versa. Title I of the Dodd-Frank Act is the vehicle through which certain financial companies can be subjected to enhanced regulation and scrutiny by the Agencies. The preparation of comprehensive resolution plans under Title I is intended to avoid the harsher resolution regime imposed by a receivership under Title II of the Dodd-Frank Act by structuring a resolution framework under Chapter 11 of the Bankruptcy Code that meets the Dodd-Frank Act s statutory objectives. These regulations, which apply to both United States and foreign companies, are also designed to provide Covered Companies and the Agencies with the tools to conduct advance resolution planning. The NPR addresses the timing of resolution plans, the minimum informational and analytical requirements for resolution plans, the regulatory review process and remediation of deficiencies and noncompliance, the submission of quarterly credit exposure reports and regulatory and private rights of action. This memorandum highlights and briefly summarizes the proposed rules. 1. Timing and Filing of Resolution Plans. Section [---].3 of the NPR 3 requires all Covered Companies to submit a resolution plan within the earlier of 180 days of the proposed regulations becoming effective, or 180 days from the date 1 Covered Company is defined under the NPR as any nonbank financial company supervised by the Federal Reserve, any bank holding company that had $50 billion or more in assets as determined by the average of its four most recent Form FR Y-9C filings, and any foreign bank or company that is a bank holding company that had $50 billion or more in assets as determined by the average of its four most recent Form FR Y-7C filings. 2 Rapid and orderly resolution is defined under the NPR as a reorganization or liquidation of the Covered Company (or, in the case of a Covered Company that is incorporated or organized in a jurisdiction outside the United States, the subsidiaries and operations of such foreign company that are domiciled in the United States) under the Bankruptcy Code that can be accomplished within a reasonable period of time and in a manner that substantially mitigates the risk that the failure of the Covered Company would have serious adverse effects on financial stability in the United States. 3 The NPR does not identify a final subpart number for the proposed rules. We have used blank references in this memo when referencing specific sections. NEW YORK WASHINGTON PARIS LONDON MILAN ROME FRANKFURT BRUSSELS in alliance with Dickson Minto W.S., London and Edinburgh

2 that a company becomes a Covered Company. 4 All Covered Companies must thereafter file a resolution plan annually within 90 days after the end of each calendar year. Unless it falls within the 90-day period in which the Covered Company must submit its annual resolution plan, Covered Companies must submit an updated resolution plan to the Agencies (within a time period specified by the Agencies but no later than 45 days) after any event, occurrence, change in conditions or circumstances or other change that results in, or could reasonably be foreseen to have, a material effect on the Covered Company s resolution plan. The Agencies are given additional discretion to require a Covered Company to submit resolution plans more frequently than required under Section [---].3 of the NPR, or to submit updates to its resolution plan when there has not been a change that would have a material effect on the Covered Company s resolution plan. In addition, the Agencies may extend the time periods under which a Covered Company is required to file or update its resolution plan, or waive the requirement to update the plan. The board of directors of each Covered Company or, in the case of a foreign-based Covered Company, a delegee with express authority from the board of directors, must approve the resolution plan before it is submitted to the Agencies. 2. Contents of Resolution Plans. The NPR prescribes a resolution plan s minimum informational, substantive and analytical components to be deemed acceptable by the Agencies. All Covered Companies organized or incorporated in the United States must include in the plan all information required by the regulations for all of its domestic subsidiaries and its foreign subsidiaries, offices and operations. Covered Companies organized or incorporated outside the United States and foreign banking organizations must include all information required by the regulations 5 with respect to the subsidiaries, branches and agencies, critical operations and core business lines that are domiciled in the United States or conducted in whole or material part in the United States. Foreign Covered Companies must also provide an explanation of how resolution planning for its U.S.- based operations is integrated into the Covered Company s overall resolution or other contingency planning process. No resolution plan may assume that the United States will provide any financial support to prevent the failure of the Covered Company. 4 The Agencies are required to issue final regulations under 165(d) of the Dodd-Frank Act not later than January 21, A foreign-based Covered Company must provide an analysis of the interconnections and interdependencies (discussed later in this memorandum) between its U.S.-based subsidiaries, operations and business lines and the foreign-based Covered Company and any foreign-based affiliates

3 The following is a list of the substantive subject-matter areas that each resolution plan must address: Executive summary, covering the key elements of the Covered Company s resolution plan, material changes from the company s most recently filed resolution plan and any actions taken to improve the resolution plan or remediate and/or mitigate its material weaknesses; Strategic analysis, incorporating a detailed description of the company s plan for rapid and orderly resolution, including, but not limited to (i) (ii) (iii) (iv) detailed descriptions of the key assumptions and supporting analyses underlying the plan; 6 the time periods that the Covered Company expects would be needed to successfully execute each material step of the resolution plan; identification and description of potential material weaknesses or impediments to effective and timely execution of the resolution plan, and proposed mitigation steps to remediate the identified weaknesses; and description of the process the Covered Company employs for determining the current market value of its core business lines, critical operations and material asset holdings, and assessment of the feasibility and impact of any sales, divestitures, restructurings, recapitalizations or other similar actions. Corporate governance relating to resolution planning, including how the resolution process is integrated with corporate governance, the Covered Company s policies and procedures regarding preparation and approval of the resolution plan, and the identity of key senior management officials responsible for overseeing various elements of the resolution plan. Organizational structure and related financial information regarding the Covered Company, including (i) (ii) description of all material legal entities and a mapping of the Covered Company s critical operations and core business lines; an unconsolidated balance sheet for the Covered Company and consolidating schedules for all entities subject to consolidation with the Covered Company; 6 Per the NPR, this includes (1) a range of specific actions to be taken to ensure a rapid and orderly liquidation under the resolution plan, (2) a plan in the event of a failure or discontinuation of a material entity, core business line or critical operation (and what actions will be taken to prevent any adverse effects of the failure on the financial stability of the United States) and (3) a strategy to protect any insured depository institution subsidiary from the risks arising from the activities of the Covered Company s nonbank subsidiaries

4 (iii) (iv) (v) (vi) (vii) description of the Covered Company s liabilities, identifying short-term and longterm liabilities, secured and unsecured liabilities, and subordinated liabilities; description of any collateral pledges or grants the Covered Company has made; description of material off-balance sheet exposures; description of the Covered Company s practices involving trading and derivatives activities; identification of the Covered Company s material hedges and a description of its hedging strategies; (viii) identification of the Covered Company s major counterparties and the interconnections, interdependencies and relationships with those major counterparties; (ix) (x) analysis of whether the failure of each major counterparty would have an adverse impact on, or result in, the Covered Company s material financial distress or failure; and information regarding the Covered Company s trading systems and payment, clearing or settlement systems. Management information systems, including a detailed inventory and description of key management information systems and applications, in particular for systems involving risk management, accounting and financial and regulatory reporting, and an identification of the scope, content and frequency of the key internal reports that senior management uses to monitor the financial health and risks of the Covered Company. Interconnections and interdependencies, identifying those interconnections and interdependencies that, if disrupted, could materially affect the funding or operations of the Covered Company. 7 Supervisory and regulatory information, identifying with appropriate contact information each federal, state, or foreign agency or authority with supervisory authority or responsibility over the Covered Company. 7 Section [---].4(g) of the NPR lists several examples of interconnections and interdependencies, including common or shared personnel, facilities or systems, capital, funding or liquidity arrangements, existing or contingent credit exposures, cross-guarantee, cross-collateral or cross-default arrangements, risk transfers, and service level agreements

5 3. Regulatory Review and Remediation; Noncompliance. The NPR provides that the Agencies will have 60 days to jointly determine, after receiving the Covered Company s resolution plan, whether the plan satisfies the minimum informational requirements under the regulations. If the resolution plan is deemed incomplete or insufficient, the Covered Company will have 30 days after receiving notice of the plan s incompleteness to resubmit the plan. After the Agencies deem the resolution plan to be minimally sufficient, the Agencies will substantively review the resolution plan. If the Agencies provide the Covered Company with notice that the resolution plan is not credible or will not facilitate an orderly resolution, the Covered Company will have 90 days 8 to revise and resubmit its resolution plan. The revised plan must describe the changes the Covered Company proposes to make to its operations to facilitate implementation of the resolution plan and explain why it believes the resolution plan is credible and would result in an orderly resolution. Under [---].7(a) of the NPR, if a Covered Company fails to submit a revised resolution plan within the specified time period, or the revised resolution plan does not remedy the deficiencies identified in the Agencies written notice, the Agencies may subject the Covered Company (or any subsidiary) to more stringent capital, leverage or liquidity requirements, or impose restrictions on the growth, activities or operations of the Covered Company or subsidiary. 9 In addition, under [---].7(c), the Agencies may direct the Covered Company to divest assets if the Covered Company has failed within a two-year period to either submit a resolution plan or adequately correct deficiencies identified by the Agencies in the resolution plan, and if the Agencies jointly determine that such divestiture is necessary to facilitate an orderly resolution if the Covered Company were to fail. 4. Quarterly Credit Exposure Reports. In accordance with 165(d)(2) of the Dodd-Frank Act, the NPR addresses Covered Companies requirement to submit credit exposure reports. Under [---].5 of the NPR, each Covered Company 10 would be required to submit a quarterly credit exposure report no later than 30 days after each calendar quarter, which includes in part the following information The aggregate credit exposure associated with (1) all extensions of credit (including loans, leases and funded lines of credit), (2) all committed but undrawn lines of credit, (3) all deposits and money placements and (4) all guarantees, acceptances or letters of credit, by the Covered Company and its subsidiaries to and from each significant company and its subsidiaries; 8 The Agencies may shorten or lengthen the 90-day period to resubmit the resolution plan either at their own discretion or upon the Covered Company s written request. 9 These additional restrictions would no longer apply once the Agencies jointly determine that the Covered Company has submitted a resolution plan that complies with all aspects of the statute and regulations. 10 Covered Companies that are incorporated or organized outside the United States (other than a bank holding company) or that are foreign banking organizations need only to include information on the credit exposure report with respect to the subsidiaries, offices and operations that are domiciled in the United States

6 The aggregate credit exposure associated with (1) all repurchase agreements, (2) all reverse repurchase agreements, (3) all securities borrowing transactions, (4) all securities lending transactions and (5) all counterparty credit exposure in connection with a derivative transaction between the Covered Company and its subsidiaries and each significant company and its subsidiaries; and The aggregate credit exposure associated with all purchases of or investments in securities issued by each significant company or its subsidiaries. 5. No Limiting Effect or Private Right of Action. Resolution plans, even if approved by the Agencies and updated in accordance with law and regulation, do not have any binding effect on (i) a court or trustee in a proceeding commenced under the Bankruptcy Code, (ii) a receiver appointed under Title II of the Dodd-Frank Act, (iii) a bridge financial company or (iv) any other authority that is authorized or required to resolve a Covered Company under any other provision of Federal, state, or foreign law. In addition, the proposed rule does not create any private right of action based on a resolution plan or any action taken by the Agencies with respect to any resolution plan. The NPR includes a number of specific questions on which the FDIC requests comment. The due date for comments on the questions and the proposed rules has not yet been published. Until publication in the Federal Register, the NPR is available on the FDIC s website. * * * * * * * * * * * * * * * If you have any questions regarding this memorandum, please contact David S. Katz ( or Marc Abrams ( or or Scott R. Tkacz ( or or the Willkie attorney with whom you regularly work. Willkie Farr & Gallagher LLP is headquartered at 787 Seventh Avenue, New York, NY and has an office located at 1875 K Street, NW, Washington, DC Our New York telephone number is (212) and our facsimile number is (212) Our Washington, D.C. telephone number is (202) and our facsimile number is (202) Our website is located at March 30, 2011 Copyright 2011 by Willkie Farr & Gallagher LLP. All Rights Reserved. This memorandum may not be reproduced or disseminated in any form without the express permission of Willkie Farr & Gallagher LLP. This memorandum is provided for news and information purposes only and does not constitute legal advice or an invitation to an attorney-client relationship. While every effort has been made to ensure the accuracy of the information contained herein, Willkie Farr & Gallagher LLP does not guarantee such accuracy and cannot be held liable for any errors in or any reliance upon this information. Under New York s Code of Professional Responsibility, this material may constitute attorney advertising. Prior results do not guarantee a similar outcome

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