FDIC Previews Paring Back Final CIDI Resolution Planning Rule

In the discussions following the presidential administration change about deregulation and paring back of post-SVB reforms, we had seen relatively little about resolution planning. That changed on Tuesday, when Acting FDIC Chairman Travis Hill previewed during a speech at the American Bankers Association Washington Summit that the FDIC intends to issue updated FAQs in the coming days related to upcoming covered insured depository institution (CIDI) resolution plan submissions. We are tracking these developments and how they impact the final CIDI resolution planning rule issued by the FDIC last year.

Based on Acting Chairman Hill's comments, the FAQs are expected to revert a significant change in the final rule, as compared to the prior rule and 2021 policy statement – the requirement for Group A CIDIs with $100 billion or more in total assets to identify a resolution strategy, which cannot be based on a resolution weekend sale, using a hypothetical failure scenario