FDIC Seeks Feedback On Improving Resolution Planning

In an advance notice of proposed rulemaking ("ANPR"), the FDIC requested feedback on improvements to agency rules that require certain insured depository institutions ("IDIs") to submit resolution plans (the "Plan Rule").

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.

In particular, 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.