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BayernLB Holding AG (Bayerische Landesbank)

Public Section of 2018 §165(d) Tailored Resolution Plan
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Public Section

a. Introduction

To promote financial stability, Section 165(d) of the Dodd-Frank Wall Street Reform and 

Consumer Protection Act (the “Dodd-Frank Act”) and its implementing rules (collectively, the 

“Rule”) 1 require, among other things, any company covered by section 165(d) to periodically 

submit to the Board of Governors of the Federal Reserve System (the “Federal Reserve” or the 

“Board”) a plan for such company’s rapid and orderly resolution in the event of material 

financial distress or failure. Included in Covered Companies are foreign-based covered 

companies, which are defined in the Rule as “any covered company that is not incorporated or 

organized under the laws of the United States.” 

BayernLB Holding AG (“BayernLB” or the “Bank”) wholly owns Bayerische Landesbank, which 

itself has more than $50 billion in consolidated global assets, and operates a New York Branch

(the “Branch”). Therefore, and as more fully explained below, BayernLB is considered a 

“Covered Company” under the Rule and must file this Resolution Plan with the Federal Reserve.

Under the requirements of the Rule, Covered Companies are required to assess their U.S. 

banking operations for the presence of Material Entities,2 Critical Operations,3 and Core 

Business Lines.4 BayernLB determined that its U.S. operations have no Material Entities, Critical 

Operations, or Core Business Lines as defined in the Rule.

b. Background

BayernLB is a large commercial bank that is majority-owned by the Free State of Bavaria 

(Freistaat Bayern). The Bank is headquartered in Munich, Germany and maintains branches, 

subsidiaries and representative offices in key international financial centers and economic 

regions. It is one of the leading commercial banks for large and mid-market commercial 

 

1 The implementing rules were jointly issued by the Federal Reserve System (the “Board”), codified at 12 

C.F.R. Part 243, and the Federal Deposit Insurance Corporation (the “FDIC”), codified at 12 C.F.R. Part 

381 (together, the “Agencies”), on November 1, 2011. 2 12 CFR 243.2(l) Material entity means a subsidiary or foreign office of the covered company that is 

significant to the activities of a critical operation or core business line (as defined in this part).

3 12 CFR 243.2(g) Critical operations means those operations of the covered company, including

associated services, functions and support, the failure or discontinuance of which, in the view of the 

covered company or as jointly directed by the Board and the Corporation, would pose a threat to the 

financial stability of the United States. 4 12 CFR 243.2(d). Core business lines means those business lines of the covered company, including 

associated operations, services, functions and support, that, in the view of the covered company, upon

failure would result in a material loss of revenue, profit, or franchise value.
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customers in Germany. The Bank serves retail customers in Germany mostly through its 

subsidiary Deutsche Kreditbank (“DKB”). 

The Bank’s minority owner is the Association of Bavarian Savings Banks (Sparkassenverband 

Bayern).

5 Because of this relationship, the Bank works in close cooperation with the Bavarian 

savings banks, offering them a wide range of products while also acting as central bank within 

the Association.

 

In the United States, BayernLB operates a federally-licensed Branch. The Branch is primarily 

regulated by the Office of the Comptroller of the Currency (“OCC”). Because it has the Branch, 

BayernLB is subject to Federal Reserve supervision as a Foreign Banking Organization under the 

Bank Holding Company Act of 1956, as amended. Because BayernLB’s total consolidated global 

assets exceed $50 billion, it is a Covered Company under the Rule and must submit a resolution 

plan that covers its U.S. operations.

 

5 As of December 31, 2017, the Sparkassenverband Bayern owns one share less than 25% of BayernLB Holding AG. 
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c. Consolidated Financial Information

The following is BayernLB’s global balance sheet as of the end of its 2017 fiscal year.
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d. U.S. Derivative and Hedging Activities

BayernLB New York Branch engages in derivative activities primarily to hedge interest rate risk 

associated with its banking book. It transacts a de minimis amount of interest rate swaps with 

existing loan customers.

e. List of Memberships in Material Payment, Clearing, and Settlement Systems

The Branch is not a member of any material payment, clearing or settlement system.

f. Description of Foreign Operations of the U.S. Branch

None. 

g. Material Supervisory Authorities

The European Central Bank is BayernLB’s primary supervisor. 

The Office of the Comptroller of the Currency (OCC) supervises BayernLB New York Branch.

Additionally, BayernLB is supervised as a Foreign Banking Organization by the Board of 

Governors of the Federal Reserve System.

h. Identities of Principal Officers

The following table sets forth the members of BayernLB’s Board of Management, as of 

December 31, 2017:

Name Role/Title

Dr. Johannes-Jorg Riegler CEO

Dr Edgar Zoller Deputy CEO

Marcus Kramer Member of the Board of Management

Dr. Markus Wiegelmann Member of the Board of Management

Michael Bücker Member of the Board of Management

Ralf Woitschig Member of the Board of Management
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i. Corporate Governance Structure and Processes Related to Resolution Planning

Authority and responsibility for developing and maintaining the Resolution Plan rests with the 

Board of Management. The Board delegated the US resolution planning responsibility to the 

General Manager of the Branch. On the basis of that delegated authority, the General Manager 

of the Branch formed a Steering Committee, comprising senior executives within the Branch 

and Head Office. The Steering Committee is responsible for overseeing resolution planning to 

meet regulatory requirements. One member of the Steering Committee (the NY Branch 

Regulatory Counsel and Head of Compliance) works with representatives from key operating 

functions and lines of business in the Branch to maintain the plan on an ongoing basis. 

The Board of Management reviewed and approved the initial filing of the Resolution Plan.

Acting on the authority delegated by the Board, the General Manager and the Steering 

Committee reviewed and approved this updated filing for 2018. 

j. Description of Material Management Information Systems

BayernLB’s management information systems (“MIS”) are applications that aggregate, analyze, 

and report financial data necessary for prudent decision making and risk management. The 

applications consist of third-party and in-house platform technologies and user interfaces that 

staff use to generate reports on both a periodic and ad-hoc basis. The key MIS at BayernLB

generate numerous reports used in the normal course of business to monitor the financial 

health, risks, and operations of BayernLB.

The ability of BayernLB’s MIS to aggregate and analyze data locally and globally is robust. 

BayernLB maintains detailed business continuity plans with respect to all technology platforms, 

including its MIS. 

k. High level Description of the Resolution Strategy for the Covered Company

The resolution strategy for the Covered Company is a liquidation of the Branch. The Branch 

would be resolved by the OCC through a receivership pursuant to the governing provisions of 

the International Banking Act of 1978 and the National Banking Act. The receivership will 

liquidate BayernLB’s U.S. assets to satisfy the claims of the Branch creditors to the fullest extent 

possible. Pursuant to this strategy, the plan outlines the asset sales that could occur during the 

resolution process. These plans include assessments as to the marketability and liquidity of the 

various classes of the Branch assets.