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Financial Services Law Insights and Observations

FDIC Reveals Banks' Living Wills

FDIC Bank Compliance Bank Resolution Living Wills

Consumer Finance

On July 3, the Federal Deposit Insurance Corporation (FDIC) posted the public sections of the initial resolution plans submitted by sixteen large bank holding companies.  The resolution plans were required by the Dodd-Frank Act.  The documents are meant to act as living wills that spell out how the banks could wind themselves down in the event of their failure.  Generally, the public portions of these plans contain an outline of the bank’s organization, assets and capital ratios, and describe in high-level detail the mechanisms that each would employ to wind up its operations in the event of failure.  The plans are subject to revisions following review by the FDIC and the Federal Reserve.

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