FDIC
Apel 12, 2016
Me. James Dimon
CChieman and Chief Executive Officer
sPMorgan Chase & Co.
270 Park Avene, 48h Floor
New York, New York. 10017-2014
Dear Mr. Dimon
(On July 1,2015, the Board of Governors of the Federal Reserve System and the Federal
Deposit Insurance Corporation (FDIC) (together, the Agencies) received the annual resolution
plan submission 2015 Plan) of JPMorgan Chase & Co. (PMC) requited by section 165(4) of
the Dodd-Frank Wall Steet Reform and Consumer Protection Act (Dodé-Frank Act),
12US. § 5365(), and the jointly sed implementing regulation, 12 CFR Pare 243 and
12 CFR Part 381 (the Resolution Plan Rule) The Agencies have reviewed th 2015 Plan aking
into consideration section 165() ofthe Dodd-Frank Act, the Resolution Plan Rule the eter that
the Agencies provided to JPMC in August 2014 (the 2014 Letter egarding JPMC's
2013 rsoltion plan submission, the communication the Agencies made to JPMC in
February 2015 clarifying the 2014 Letter (the 2015 Communication), other guidance proved by
the Agencies, and other supervisory information available tothe Agencies.
In reviewing the 2015 Plan, the Agencies noted improvements over prior resolution plan
submissions of JPMC, Nonetheless, the Agencies have jointly determined pursuant to
section 165(4) ofthe Dode-Frank Act and section (6) of the Resolution Plan Rule thatthe2015 Plan isnot credible or would nt facilitate an orderly resolution under the U.S. Bankruptey
‘Code. Section Il ofthis letter identifies the aspects ofthe 201 Plan thatthe Agencies jointly
The 2015 Communication epi advised that rnsning actos required bythe Agencies in be 2014 Leter
the 2015 Communication wo improve slaty geeraly re expect to be complete o ater thanand JPMC
‘wholeste fundin
+ Since the 2015 Plan submission, JPMC has compliod withthe clean holding
‘company guidance from the 2014 Lette and 2015 Communication. In addition,
the firm has improved its overall eaptal position,
+ JPMC has enhanced colter! management information stems, ening i 10
track he sources and uses of it secures clit A=
trapped intemal and extra Shred sevice dependents (retusa
‘Scbricalinfasteture sjtemeinfelloctal property and ele) has
locument eal ncaa services in eal agreement that contain ems
incon ensure it thee Srvices woud continue in recolored has
invented in elton specific managament information stems
rand as adered 0 the Interation
Derivatives Association 2075 Universal Resolution Stay Protocol
Deficiencies and Remediation
Notwithstanding the noted progress JPMC has made to dats, the Agencies jointly
identified four specs ofthe 2015 Plan that are deficient.
Laquiprry
‘The Agencies identified a defcieney regarding iquidity inthe 2015 Plan. As described
below, JPMC does not have appropriate models and processes for estimating and maintaining
sufficient Liquidity’ at, or readily available 0, material entities, or for estimating its liquidity
needs to fund its material entities during the resolution peti,
rial en” ad “el operations” refer to th eral ees, a ital operations dent in teAesltion Lgl Adequacy nd Poston (LAP): TAA sot esa
ee
available to, material entities in resolution (RLAP model). ‘This is notable given JPMC’s:
ligt poe in 2015 Plan, which ris onthe ems by shi substantial amount of
ss
‘sam iuseion of is defeny inthe f’sRLAP model PMCs 2015 Planted
on covey SII oF parent quit support being injected into various material ents,
icing nS. woke ln, dsing th prod nme cig PMCs arty
ee
feng ings of iain, For campls ude the 2015 Pan, PMC mc plans
vite :h 7 EE
SRE epost A «I bach 08 oF the date ofthe 2015 Plan, If
all ora portion of the funds deposited at the branch are not etued othe parent in a
timely mannee—e-g, due to defensive ring feng EAI sc parent sey
not have access to sufficient fund to support the recapitalization or funding needs of key
lading
ents, The sso ing-fencing is heightned by the stand-alone guidity isk
profit of te I ranch, i
thi partes that intent with he branch dicey, (0) EI, wi
lends substantial amounts of ovemight fund directly othe branch, and (C) to
h in stress could be exposed to subst
outflows: (A) to
1 “Moet wrote ae of calito estimating he mt iii surf at cch ea nity an forthe
fm in agreate aed on aston regarding vaio uid, hsql gd ese (HOLA), andEe a
BE no be mstcis sn EIT ‘nin
Specifically, with espct to (C) above, the Financial interconnectedness between the
HE onc ond IE prescnts noble challenges, The branch as commited to
RN EA 2h: outa be craw up tothe fa AY amount or up
(oI acison, there are substantia funding ows between the EL
branch and nthe 2015 Plan. For example, the I beanch receives SIM of
support fom EE. tile proving SE of Financial supporto A. The
‘magnitude and nature of this interconnectedness highligh he
od forthe REAP model to have