Under the Dodd-Frank Act, passed in the wake of the 2008 financial crisis, systemically important financial institutions must submit detailed blueprints, commonly called “living wills,” showing how they could be dismantled without triggering a broader financial meltdown.

UBS has been filing US resolution plans since 2012, with annual updates running through 2021 focused on the orderly wind-down of its US operations through UBS Americas Holding LLC. These plans are primarily reviewed by the Federal Reserve and the FDIC.

When UBS absorbed Credit Suisse in 2023, it didn’t just inherit assets and clients. It inherited an entirely separate web of legal entities, counterparty relationships, and regulatory obligations across dozens of jurisdictions.

As of October 2024, FINMA mandated revisions to UBS’s Swiss recovery plans, specifically demanding better liquidity strategies to account for the post-merger reality. The Swiss regulator also suspended certain assessments through 2024 to give UBS time to work through the integration complexities.