Max Bonici and Chelsie Rimel published “Federal Deposit Insurance Corporation Finalizes Large Bank Resolution Plan Rule and Office of the Comptroller of the Currency Proposes Changes to Recovery Plans” in the October issue of The Banking Law Journal. The following is an excerpt:
The Federal Deposit Insurance Corporation (FDIC) has finalized its resolution planning rule for large banks, which became effective October 1, 2024. Resolution plans, or “living wills,” are plans to wind down operations in the event of bank failures. The current rule requires covered insured depository institutions (CIDIs) with $50 billion or more in total assets to periodically submit resolution plans to the FDIC. The FDIC has made key changes based on its experience with the filings over the last decade generally and the 2023 spring bank failures specifically.