The FDIC modified its approach to implementing FDIC Rule 360.10 ("Resolution plans required for insured depository institutions with $50 billion or more in total assets"). In the Policy Statement, the FDIC provides details on streamlining content requirements for certain insured depository institutions ("IDIs") plan submissions and to "emphasize periodic engagement, in an effort to provide greater utility in planning for a resolution."
The FDIC stated that the modified approach exempts filers from certain content requirements that are not particularly useful or that can be obtained through other supervisory channels. The FDIC said it will continue to maintain critical content requirements that have aided FDIC staff in developing resolution strategies for IDIs.
The FDIC clarified that each covered filer will receive a letter specifying the exempted plan content and when the next filing is due. Further, the FDIC explained that the resolution plans will be submitted in separate groups of (i) IDIs with top tier parent companies that are not U.S. global systemically important banks or "Category II" banking organizations as outlined under FRS Rule 252.5 ("Categorization of banking organizations") and (ii) "all other IDIs" with assets totaling $100 billion or more.
The FDIC further explained that it will exempt filers from certain content requirements on a case-by-case basis depending on an assessment of how valuable or material the information provided would be in planning to resolve an IDI.
The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.