Dodd-Frank act resolution plan final rule and interim FDIC final rule on resolution of large insured depository institutions

September 2011

Initial Summary of Some Key Issues for Foreign Banking Organizations

At its meeting on September 13, 2011, the board of the Federal Deposit Insurance Corporation approved a Final Rule on resolution plans required by the Dodd-Frank Act for systemically important financial institutions. The Federal Reserve Board is also expected to approve the Final Rule in the near future. (The Dodd-Frank Act requires the rule be jointly approved by the two agencies.)

The Federal Reserve Board and Federal Deposit Insurance Corporation issued a Proposed Rule that was published in the Federal Register on April 22, 2011, and the comment period ended on June 10, 2011. The Dodd-Frank Act Final Rule reflects a number of changes from the Proposal in response to comments, including from foreign banks. The bad news/good news for foreign banks that were covered by the Proposal is that they will still have to file resolution plans, but the timing and scope of resolution plan submissions has been extended and reduced for foreign banks with limited US nonbank assets.

Contact us

Gary Meltzer
US Asset and Wealth Management Leader
Tel: +1 (646) 471 8763

Dan Ryan
US Banking and Capital Markets Leader
Tel: +1 (646) 471 8488