Operational Planning

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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Systemic Resolution Framework

 The FDIC has established a comprehensive operational framework 

for responding to the threat of a failing SIFI and executing our 

systemic resolution authorities

 Actions and processes that need to be carried out from the time 

contingency planning begins through exit from resolution

 Designed to be flexible and responsive to different types of 

institutions and scenarios

 Heightened attention when recovery or bankruptcy resolution is more likely

 Processes adapted to the unique facts and circumstances of any SIFI’s 

failure

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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Operational Exercises

 The FDIC has been conducting an ongoing series of 

operational exercises to evaluate and test our processes

 Builds on inter-agency exercises and other work with domestic 

and foreign authorities

 Program of operational exercises will continue on a regular 

basis going forward

 Test alternate scenarios and resolution strategies

 Familiarize new personnel with operational processes

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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Systemic Resolution Phases

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.

Phase Summary

Planning Phase

• Risk monitoring and supervision

• Advanced resolution planning: internal, domestic, international

• Early recovery actions •

Contingency Resolution Planning Initiated

Determination 

Phase

• Activation of resolution management infrastructure: internal, domestic, 

international

• Information requests for SIFI and authorities

• Resolution strategy, capital, and liquidity analysis

• Identification of new management

• Legal document preparation, board case, appointment process (“key turning”)

FDIC Appointed Receiver
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Systemic Resolution Phases (cont.)

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.

FDIC Appointed Receiver

Immediate 

Stabilization Phase

• Receivership and Bridge formation

• Appointment of new Board and senior officers 

• Capital and funding stabilization

• Communications: public, regulators (including host authorities) and policy 

makers, firm personnel, and customers and service providers

Bridge Institution Stabilized

Orderly Liquidation 

Phase

• Bridge oversight

• Valuation, fairness opinion, and new financials

• Liquidation actions and restructuring plan

• Fulfillment of regulatory requirements needed to exit resolution, if applicable

• Claims process and distribution to creditors

Bridge Terminated / Exit From Resolution

Post-Exit Phase

• Completion of restructuring plan

• Ongoing receivership management

• Post-exit communications and reporting