The Federal Reserve and the FDIC approved a final resolution
planning rule (the "Final Rule") significantly revising the
original rule adopted in 2011.1 The Final Rule revamps
the 2011 requirements by aligning the timing and certain
requirements for resolution planning with the filer's
categorization under the Federal Reserve's October 10th final
tailoring rule. Most significantly, the Final Rule allows all
filers to submit more targeted or reduced resolution plans, rather
than full plans, in their next submission, generally streamlines
content requirements for many filers, and creates new waiver and
related procedures that could permit further tailoring of
requirements based on the potential systemic significance of
different filers. The Final Rule largely adopts the April proposal,
but provides important clarifications and procedural
improvements.
