The regulatory community has been abuzz with the notion of living wills, or firm specific resolution plans, for most of this year (see here for some of the discussions), but most have not considered the data management responsibilities inherent in the process. Daniel Tarullo, member of the board of governors of the US Federal Reserve System, addressed this issue and highlighted the counterparty data management challenge during a speech to the Institute of International Bankers Conference on Cross-Border Insolvency Issues in New York at the start of November.

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