Kate Wellman authored Reuters article, “FDIC final resolution planning rule increases requirements on large insured depository institutions”
Moore & Van Allen (MVA), Financial Regulatory Advice and Response Member, Kathryn Wellman authored the article, “FDIC final resolution planning rule increases requirements on large insured depository institutions”, which was published by Reuters and Westlaw Today on August 12.
The article
On June 20, 2024, the Federal Deposit Insurance Corporation (FDIC) issued a final rule (Final Rule) which will significantly increase the resolution planning requirements under 12 CFR § 360.10 on covered insured depository institutions with $50 billion or more in total assets (CIDIs).
The Final Rule responds to the FDIC's experience in the 2023 bank failures and is largely unchanged from the FDIC's September 2023 proposal (Proposed Rule), with limited revisions to the frequency and required content of submissions. The few changes and FDIC's responses to comments received on the Proposed Rule indicate it is preserving the flexibility to further develop its resolution planning expectations based on its review of submissions beginning in 2025 and engagement with CIDIs.
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