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More liquidity, resolution 'playbooks' in latest BofA living will

said in aliving will remediation release that it had added about $76 billion inliquidity resources since the end of 2014 as part of its effort to correctdeficiencies in its living will.

Thecompany also said in a public submission released by the FDIC that it hadimproved its ability to measure the standalone liquidity position of itsmaterial subsidiaries on a 90-day stress horizon, as well as test the liquidityneeds of those businesses on a daily basis and during a resolution scenario.

Thoseactions were a response to previous regulatory feedback that the company'sliquidity planning in its living will was deficient. Regulators also arguedthat the bank's governance plans did not include capital and liquidity triggersthat would allow regulators to execute a single-point-of-entry resolution ifthe bank became insolvent.

Thebank said in its submission that it established triggers for liquidity andcapital actions that would allow the bank's businesses to operate in the wakeof a bankruptcy filing, in addition to creating a "comprehensive set ofplaybooks" outlining steps needed if the bank nears a resolution scenario.

Thebank took other actions to shore up areas that regulators had deemed"shortcomings" in its living will. It noted that it had simplifiedits overall legal structure by eliminating 40 intermediate holding companiessince 2011, and said that it plans to eliminate 20 more. It also strengthenedits plans for winding down its derivatives and trading activities under aresolution scenario.