As they implement S. 2155, the Federal Reserve and the FDIC said on Monday that they are beginning the process of determining which financial firms with assets of less than $250 billion will be subject to the requirement to submit resolution plans, also known as living wills. Under S. 2155, the Federal Reserve is no longer required to impose the living will process on bank holding companies with less than $100 billion during the first 18 months following the bill’s passage. After the 18-month period, or sooner at the discretion of the Fed, the requirement ends for bank holding companies with assets below $250 billion.

As recommended by ABA in a February comment letter, the agencies also extended the deadline for 14 U.S. regional banking companies to submit their resolution plans. Originally due by the end of 2018, living wills will be due by Dec. 31, 2019, in order to allow more time for the agencies to provide feedback on their last round of resolution plans. ABA has urged--and Fed Vice Chairman for Supervision Randal Quarles has signaled that he wants to pursue--a biennial rather than annual living will process.

The 14 companies receiving the extension are Ally Financial, American Express, BB&T Corporation, Capital One Financial, Citizens Financial, Fifth Third Bancorp, Huntington Bancshares, KeyCorp, M&T Bank, Northern Trust, Regions Financial, SunTrust Banks, PNC Financial Services Group, and U.S. Bancorp. Last week, the Fed and FDIC also sought public comment on living will guidance for the largest U.S. financial institutions. Read more. Read ABA's comment letter. For more information, contact ABA's Hu Benton.