Jpmorgan Chase (PDF)
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Introduction 1 Resolution Planning and Why JPMorgan Chase Is Resolvable 3 Our Resolution Plan Shows We Can Be Orderly Resolved 5 Our Single Point of Entry Resolution Strategy Enables Orderly Failure Without Government or Taxpayer Support or Harm to the U.S. Economy 14 Our Resolution Plan Is Designed to Meet Real World Challenges 25 FAQs 52 JPMorgan Chase Enhancements to Resolvability 68 Overview of JPMorgan Chase 73 Other Required Financial Information Disclosures in the Public Filing 121 Glossary 135 Introduction Defined terms are capitalized and may be found in the Glossary beginning on page 135. Our 2019 Resolution Plan Public Filing presents a high-level overview of our detailed, confidential resolution plan that we filed with the Federal Reserve and the FDIC, together referred to as the Agencies. Both the Public Filing and our confidential resolution plan provide a roadmap of how our core businesses and operations would continue to operate, or be wound down in an orderly manner, in a resolution event without jeopardizing the economy or global financial markets, or requiring any extraordinary government assistance or taxpayer support. We last submitted a resolution plan in July 2017. In December 2017, the Agencies provided our firm with joint feedback that our July 2017 resolution plan submission adequately remediated the shortcomings they had identified and no further shortcomings or deficiencies were identified. The Agencies also identified four areas common to all U.S. G-SIB filers where more work may be needed to improve the resolvability of firms: intragroup liquidity, internal loss absorbing capacity, derivatives, and payment, clearing and settlement activities. In December 2018, the Agencies jointly issued the Final Guidance, which described the Agencies’ expectations regarding key vulnerabilities in resolution plans and updated aspects of prior guidance. The Final Guidance is organized around a number of key vulnerabilities in resolution: capital; liquidity; governance mechanisms; operational (including payment, clearing and settlement activities); legal entity rationalization and separability; and derivatives and trading activities. We have made key enhancements to better respond to this Final Guidance, including the new requirements, in addition to our own continued efforts to improve our resolvability. We have had constructive dialogue with the Agencies about our efforts to make meaningful resolvability improvements across our firm to ensure that we meet the requirements set out by the Agencies, and we have undertaken specific enhancements in addition to those requirements that are tailored to our particular business model. In developing and delivering this plan, we believe that: our resolution plan responds fully to all feedback received to date from the Agencies and addresses the Final Guidance and the 165(d) Rule; our resolution plan meets the high standards established by our firm for addressing our resolvability; we are well positioned financially with loss absorbing resources and high quality liquid assets to withstand a variety of extreme loss scenarios; we have appropriate triggers, governance and reporting capabilities in place, coupled with the operational capabilities necessary to execute our Single Point of Entry strategy if ever needed; and our resolution-based assumptions and options are appropriately conservative and are meaningfully supported through robust governance, review and challenge. Taken together, we believe that our resolution plan is credible. 1 Introduction This Public Filing provides an expanded overview of: our resolution planning; how JPMorgan Chase is resolvable; frequently asked questions about resolution; key enhancements we have made to JPMorgan Chase’s resolvability; key facts and information about JPMorgan Chase; and other financial information disclosures required for resolution public filings. 2 Resolution Planning and Why JPMorgan Chase Is Resolvable Resolution Planning and Why JPMorgan Chase Is Resolvable TABLE OF CONTENTS Our Resolution Plan Shows We Can Be Orderly Resolved ...................................................................................... 5 Our firm and other systemically important financial institutions can be resolved in an orderly manner. .................. 5 Financial strength supports our resolvability. .......................................................................................................... 5 An orderly resolution requires proper planning. ...................................................................................................... 8 An effective resolution plan must provide a roadmap to key stakeholders for successful implementation in a crisis. .............................................................................................................................................................. 8 Our Single Point of Entry Resolution Strategy Enables Orderly Failure Without Government or Taxpayer Support or Harm to the U.S. Economy ............................................................................................. 14 Single Point of Entry is optimal for resolving large financial institutions in an orderly manner in bankruptcy. ....... 14 Our Single Point of Entry strategy would limit the destabilizing effects of a possible failure by avoiding bankruptcy for the firm’s subsidiaries. ............................................................................................................. 15 Our extensive financial forecasting helps us confirm that our firm has sufficient financial resources to execute Single Point of Entry successfully. ..................................................................................................... 20 Single Point of Entry would result in a simpler and smaller firm. ........................................................................... 22 Our Resolution Plan Is Designed to Meet Real-World Challenges ........................................................................ 25 We have sufficient capital to successfully implement the strategy. ....................................................................... 26 Our liquidity is sufficient to implement our strategy successfully. .......................................................................... 28 Key decision makers throughout the firm understand how to implement our Single Point of Entry strategy in a timely manner. .......................................................................................................................................... 31 Our strategy can withstand legal challenge. ......................................................................................................... 33 Our operations will continue uninterrupted in a crisis. ........................................................................................... 37 We have simplified our structure to support our strategy. ..................................................................................... 42 We have optionality in how our firm could execute divestitures in resolution. ....................................................... 44 We have mitigated challenges to resolution posed by our derivatives portfolio and prime brokerage activities. .......................................................................................................................................................... 47 We cooperate and coordinate with key stakeholders around the world so that they understand and support our Resolution Plan. ........................................................................................................................................ 50 4 Resolution Planning and Why JPMorgan Chase Is Resolvable Our Resolution Plan Shows We Can Be Orderly Resolved Defined terms are capitalized and may be found in the Glossary beginning on page 135. We recognize our responsibility to continually strengthen and health of the U.S. financial system and and safeguard our firm, given its vital role in the United economy; and States and global financial system. This sense of responsibility is embedded in the way we do business, without extraordinary government assistance or any and shapes our day-to-day operations, as well as our taxpayer support. strategic planning for the future. We have continued to make significant changes since our last Resolution Our resolution plan shows how these goals can be Plan—the Public Filing of which is linked here—to ensure achieved for JPMorgan Chase. our resiliency and resolvability. We want to take this opportunity to describe our progress so that our clients, employees and communities can be even more confident Financial strength supports our in us in times of stress. resolvability. Ensuring our resolvability begins with minimizing the risk In this section of this Public Filing, we: of failure. We have substantially strengthened our outline our resolution plan and why we believe it is financial resilience and further reduced the possibility of credible; failure in a financial crisis through many initiatives. Among these efforts has been the accumulation of describe how we have a robust resolution strategy extensive loss absorbing resources. that will shield the U.S. financial system and economy from harm and U.S. taxpayers from losses Successfully executing our Resolution Plans requires in the highly unlikely event of our failure; and maintaining sufficient funding and liquidity to respond to a crisis. We measure our funding and liquidity by