I very modestly like living wills, though they seem like a bother that would have to constantly be amended each time a bank's positions change. The Fed and FDIC rejected every living will submitted to them by a big bank last week, and we will outsource commentary to Stephen Lubben:
take a look at something like JPMorgan Chase’s recently released living will — or at least the bit that we are allowed to see.
Under the heading of “material entities” we are apprised of more than two-dozen legal entitles, and a host of branches, too. The relationship between these entities is not always clear — let’s hope the Fed and the F.D.I.C. get an org chart — but the names of several foreign jurisdictions pop up, as do some special treats, like the entity incorporated in Delaware that operates primarily out of its London branch. That would be an interesting Chapter 11 case.
The report also shows that “securities sold under agreements to repurchase” remains the single largest source of funding for JPMorgan after equity, representing some $155 billion of its total funding package. As others have noted, repurchase agreements were at the very heart of financial crisis.
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