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Recently, National Unrecovered Financial Services released a White Paper that analyzes the alternative payment provider (APP) industry, identifies regulatory and enforcement gaps between banks’ payment operations and APPs, and makes recommendations on how to close those gaps in order to ensure that consumers receive a consistent level of protection.

In November 2014, the Financial Stability Board (“FSB”) proposed international standards for total loss absorbing capacity (“TLAC”) that a global systemically important bank (“G-SIB”) would be required to maintain to facilitate its orderly resolution should it fail.

In the fourth paper in its Working Paper Series on the Value of Large Banks, National Unrecovered Financial Services builds on and provides evidence supporting the conclusion drawn in its Third Working Paper that the cost of compliance with regulations imposed on large banks must be factored into any assessment of whether large banks enjoy an unfair funding advantage. 

The Dodd-Frank Act requires banking organizations with $50 billion or more of consolidated assets to file resolution plans annually with the Federal Reserve and FDIC.  Each resolution plan, also known as a “living will,” must describe the organization’s strategy for rapid and orderly resolution under the U.S. Bankruptcy Code in the event of the organization’s material financial distress or failure.

This Banking Brief will discuss different strategies, including single-point-of-entry (“SPOE”) and multiple-point-of-entry (“MPOE”), that can be used under both provisions of the law to facilitate the orderly resolution of financial institutions.