SYSTEMIC

RESOLUTION 

ADVISORY COMMITTEE

Resolution Planning for Broker-Dealers 

and CCPs
SYSTEMIC

RESOLUTION 

ADVISORY COMMITTEE

Resolution Planning for Broker-Dealers and CCPs

2020 SRAC 26

• Unique challenges: lack of direct supervisory authorities and access to key 

data, and Title I resolution plans (in certain cases).

• Strategies:

• Develop strong partnerships with supervisors and other relevant 

stakeholders, both domestic and international

• Manage and update data sharing arrangements

• Develop resolution strategies matching activity/institution type

• Monitor market events internally and with stakeholders
SYSTEMIC

RESOLUTION 

ADVISORY COMMITTEE

Orderly Resolution of a Broker-Dealer

2020 SRAC 27

• The Federal Reserve and SEC are authorized to issue a recommendation to the Secretary of the 

Treasury for the resolution of a broker-dealer under Title II, after consulting the FDIC.

• Outside of Title II, the liquidation of a broker-dealer typically would be subject to the 

Securities Investor Protection Act of 1970 (SIPA).

• The orderly resolution of a broker-dealer under Title II would seek to:

• Avoid or mitigate the serious adverse effects on financial stability in the U.S. that would 

result from the failure of the broker-dealer and its liquidation under SIPA.

• Ensure that all customer claims relating to, or net equity claims based upon, customer 

property or customer name securities are satisfied in a manner and in an amount at least 

as beneficial to customers as would have been the case if the broker-dealer were 

liquidated under SIPA.

• The FDIC and SEC collaborated closely to jointly issue a final rule governing the resolution of a 

broker-dealer under Title II.
SYSTEMIC

RESOLUTION 

ADVISORY COMMITTEE

• The Federal Reserve and the FDIC are authorized to issue a recommendation to the Secretary 

of the Treasury for the resolution of a systemically important CCP under Title II.

• The orderly resolution of a CCP under Title II would seek to:

• Avoid or mitigate the serious adverse effects on U.S. financial stability that could result 

from the failure of the CCP

• Maintain the provision of critical clearing functions

• Key challenges to CCP resolution under Title II may include:

• Potentially short runway for placing a CCP in resolution

• Potential challenges in identifying sufficient resources and tradeoffs in using those 

resources

• Potentially limited resolution options

Orderly Resolution of a CCP

2020 SRAC 28
SYSTEMIC

RESOLUTION 

ADVISORY COMMITTEE

FDIC planning work focuses on identifying and mitigating key challenges to CCP 

resolution, including through internal workstreams and collaboration with other U.S. 

agencies, foreign authorities, and multilateral international organizations.

• Institution-specific: Co-hosts Crisis Management Groups (CMGs) with U.S. oversight 

authorities and participates in CMGs for foreign CCPs.

• Bilateral: Engages with U.S. oversight authorities and foreign CCP resolution 

authorities on areas of mutual interest.

• Multilateral: Participates in the Financial Stability Board (FSB) Resolution Steering 

Group (ReSG) and co-Chairs the FSB’s Cross-Border Crisis Management Group for 

Financial Market Infrastructures (fmiCBCM).

CCP Resolution Planning

2020 SRAC 29