Title II Planning Update

April 14, 2016

Privileged and confidential; staff level discussion draft; not for further distribution. The information contained herein does not reflect, and cannot 

be relied upon as evidence of any agency or departmental position. Any resolution strategies or measures discussed herein are preliminary in 

nature and do not necessarily reflect actions that would or would not be taken in any particular resolution under any law, rule or regulation.
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Summary of 2012 Title II Planning

Privileged and confidential; staff level discussion draft; not for further distribution. The information contained herein does not reflect, and cannot be relied 

upon as evidence of any agency or departmental position. Any resolution strategies or measures discussed herein are preliminary in nature and do not 

necessarily reflect actions that would or would not be taken in any particular resolution under any law, rule or regulation.

ABC Holding 

Company

Banks Broker/Dealer Other

ABC Bridge

Holding 

Company

Banks Broker/Dealer Other

Newco Holding 

Company

Banks Broker/Dealer Other

Receivership Conversion

Most/all assets + some liabilities All assets + liabilities 

Needed Improvements: 

 Exit of a non-systemic enterprise

 International close out of derivative 

contracts 

Goals Accomplished: 

 Financial Stability

 Write-down of impaired creditors

 Wipeout equity holders

 Termination of culpable management

 No taxpayer support 
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December 2013 Federal Register Notice:

Resolution of Systemically Important Financial Institutions: The 

Single Point of Entry Strategy

Privileged and confidential; staff level discussion draft; not for further distribution. The information contained herein does not reflect, and cannot be relied 

upon as evidence of any agency or departmental position. Any resolution strategies or measures discussed herein are preliminary in nature and do not 

necessarily reflect actions that would or would not be taken in any particular resolution under any law, rule or regulation.

 “The restructuring might result in one or more smaller companies that would 

be able to be resolved under bankruptcy without causing significant adverse 

effects to the US economy.” 

 “The exact path through resolution will vary depending on the particular failure scenario, 

but we would expect some business lines or subsidiaries (such as broker-dealers) to quickly 

shrink and wind down, and for others to be sold off.” 

 “[S]hareholders, creditors, and culpable management of the firm will be held accountable 

without cost to taxpayers; and... institution[s] can be would down and liquidated in an 

orderly way.” 

November 2015 Chairman Gruenberg 

Speech*:

*The Clearing House Annual Conference in New York, NY November 18, 2015 

 
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Current Title II Planning Focus: Optionality

Privileged and confidential; staff level discussion draft; not for further distribution. The information contained herein does not reflect, and cannot be relied 

upon as evidence of any agency or departmental position. Any resolution strategies or measures discussed herein are preliminary in nature and do not 

necessarily reflect actions that would or would not be taken in any particular resolution under any law, rule or regulation.

ABC Holding 

Company

Banks Broker/Dealer Foreign 

Broker-Dealer

ABC Bridge

Holding 

Company

IPO SPIN SALE

Bank

Receivership

Most/all assets + some liabilities 

US

Broker-Dealer Asset Mgmt

Wind down Wind down Sale

Foreign 

Broker-Dealer

Multiple Options: 

 Sale of Subsidiaries

 Sale of Assets 

 IPO of Entities

 Wind down of Entities

 

ASSETSALES BRANCH SALES

Asset Mgmt