In accordance with the Dodd-Frank Wall Street Reform and Consumer Protection Act, twelve of the largest U.S. Banks (generally those with $100 billion or more in U.S. nonbank assets) have filed their Resolution Plans (living wills). Last year the Federal Reserve and FDIC did not view most plans favorably.
Other companies that become subject to the rule after November 30, 2011, including the nonbank financial companies designated by FSOC, also must submit on or before July 1. All other firms are required to submit their plans on or before December 31 each year. (Requests for extensions are reviewed by the Board and the FDIC and have been granted in limited instances.)