Deutsche Bank

2020 U.S. Resolution Plan

Public Section | September 29, 2020

 

1.

Introduction 


Public Section | September 29, 2020 6

Specifically, we accomplished the following:

— Remediation of Governance Mechanisms 

Shortcoming: We remediated the Governance 

Mechanisms Shortcoming that the Agencies 

identified in their December 2018 Feedback 

Letter regarding our escalation triggers – 

specifically that we, by the time of this 2020

U.S. Resolution Plan submission, should 

include capital triggers in DB USA’s Trigger 

and Escalation Framework that explicitly take 

into account forecasts of losses and other 

balance sheet changes that would occur in the 

Resolution phase; and

— Completion of Enhancement Projects: 

We completed the implementation of 

Enhancement Projects, which are resolution 

enhancement initiatives that we developed in 

response to the Agencies’ December 2018 

Feedback Letter, as well as other initiatives.

We hereinafter summarize the information described 

in more detail in our 2020 U.S. Resolution Plan on 

each of these improvements in turn.

Group Resolution Strategy versus

U.S. Resolution Strategy

The Group Resolution Strategy for DBAG has

been developed by the European Single

Resolution Board and the German Bundesanstalt 

für Finanzdienstleistungsaufsicht, in cooperation

with other DB Group regulators. Under the Group

Resolution Strategy, DBAG would be recapitalized

by bailing in its external capital and debt

instruments (i.e., writing them down or converting 

them to equity), which would recapitalize DBAG 

and otherwise keep DBAG’s subsidiaries and 

branches, including its U.S. Operations, open and 

operating outside their own bankruptcy or 

resolution proceedings. Within one month after 

the bail-in, DBAG would be required to establish a

business reorganization plan addressing the

causes of failure and aiming to restore the 

institution’s long-term viability.

The United States takes a different approach to

resolution planning from the European regulators.

In the United States, we are required to prepare 

and submit our own resolution plan to the 

Agencies under the U.S. Bankruptcy Code. The

FDIC prepares its own separate plans for each 

firm under Title II of the Dodd-Frank Act. For a

foreign banking organization like DBAG, the U.S.

Resolution Plan covers only the U.S. Operations

and must reflect certain assumptions specified by 

the Agencies that are different from those in our 

Group Resolution Strategy, including that the U.S. 

Operations would not receive any financial 

support from DBAG, our foreign parent company. 
2. 

Remediation of 

the Governance 

Mechanisms 

Shortcoming 


3. 

Completion of 

Enhancement Projects 
Public Section | September 29, 2020 11

3. Completion of

Enhancement Projects

In addition to the remediation of the Governance Mechanisms Shortcoming, 

we completed the implementation of Enhancement Projects since the 

submission of our 2018 U.S. Resolution Plan. As part of this process, we 

developed and approved action plans for each of these projects. Thereafter, 

our U.S. Living Wills OpCo and U.S. Living Wills team oversaw the 

implementation and closure of the Enhancement Projects.

Each of our Enhancement Projects is aligned to one of the three 

pillars of our approach to resolution capabilities:

— Financial Resiliency

— Structural Enablement

— Operational Continuity

We described and discussed these three pillars in detail in the public 

section of our 2018 U.S. Resolution Plan and have continued to 

follow our three pillar approach since its submission.

The Three Resolution Capabilities

We believe that the three 

pillars of our resolution 

capabilities enable us to 

operationalize our U.S. 

Resolution Strategy when 

and if required.

Deutsche Bank 

2020 U.S. Resolution Plan


4. 

U.S. Resolution 

Plan Governance 
Public Section | September 29, 2020 15

Deutsche Bank

2020 U.S. Resolution Plan

4. U.S. Resolution

Plan Governance

Generally, the DBAG Management Board has delegated authority to 

management in the U.S. to oversee and manage the U.S. resolution planning

activities in coordination with efforts at the DB Group level.

Christiana Riley, a member of the DBAG Management Board and the Chief Executive Officer of DB USA, briefed

the DBAG Management Board on the 2020 U.S. Resolution Plan, including its content and submission, on 

September 22, 2020. Additionally, the Head of U.S. Living Wills periodically briefed the DB USA Board of 

Directors on the U.S. Resolution Plan, including on September 25, 2020. Acting under the authority delegated to 

her by the DBAG Management Board and in reliance on the briefings received by the DBAG Management Board 

and the DB USA Board of Directors, as well as her own review of the 2020 U.S. Resolution Plan, Christiana Riley 

considered and approved the 2020 U.S. Resolution Plan on September 25, 2020. 
5. 

Conclusion 
Public Section | September 29, 2020 17

5. Conclusion

As a result of the implementation and completion of the foregoing projects, we 

believe that we have remediated the Governance Mechanisms Shortcoming 

identified by the Agencies in the December 2018 Feedback Letter. We also 

further enhanced the resolvability of our U.S. Operations by building additional 

and improving existing resolution capabilities.

The efforts that we have made, and will continue to make, underscore our commitment to enhancing the 

resolvability of our U.S. Operations and our desire to simplify them and focus on our core strengths.

Deutsche Bank 

2020 U.S. Resolution Plan
6. 

Glossary