An FDIC request for feedback on improving an agency rule that mandates certain insured depository institutions ("IDIs") to submit resolution plans (the "Plan Rule") was published in the Federal Register. Comments must be submitted by June 21, 2019.

As previously covered, the Plan Rule requires an IDI with over $50 billion in total assets to submit a resolution plan that allows the FDIC to resolve the IDI in the event of its insolvency. Specifically, the FDIC seeks comments on certain approaches under consideration, including:

  • the creation of "tiered resolution" planning requirements contingent upon size, complexity and other factors;
  • revisions to the frequency and content of plan submissions; and
  • enhancements to the process for "periodic engagement" between the FDIC and institutions subject to the rule.

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