AFR’s Comment to the FDIC and Federal Reserve on Resolution Plans
AFR submitted a comment to the FDIC and the Federal Reserve on the rules implementing the Dodd-Frank requirement that companies submit “living wills” and records of credit exposures. “Living Wills” are plans detailing how the company could be resolved through the bankruptcy process without a need for government intervention. AFR supported the rules but suggested they be strengthened by requiring planning for situations of market stress and also by establishing more thorough and continuous records of credit exposures.