What is the future for Recovery & Resolution Planning – aka Living Wills? In August 2014 two U.S. regulators, The Federal Reserve and The Federal Deposit Insurance Corpn, issued rejections of living wills submitted by eleven of the largest U.S. and foreign banks. In March 2015 the same regulators also rejected plans submitted by a further three non U.S. banks. The European Banking Authority (EBA) has demanded further insight into financial contracts, publishing a consultation paper on 6 March 2015 with a minimum set of information required, effectively a retort to the industry’s poor attempts.
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