WASHINGTON – The Federal Deposit Insurance Corporation today outlined a modified approach to implementing its rule requiring certain insured depository institutions (IDIs) to submit resolution plans to facilitate resolution under the Federal Deposit Insurance Act. The modified approach applies to IDIs with $100 billion or more in total assets, extends the submission frequency to a three-year cycle, streamlines content requirements, and places enhanced emphasis on engagement with firms.
The modified approach preserves key content requirements that have helped FDIC staff develop resolution strategies for IDIs, but exempts filers from other content requirements that have been less useful or are obtainable through other supervisory channels. On a case-by-case basis, the FDIC also plans to exempt filers from certain content requirements based on its evaluation of how useful or material the information would be in planning to resolve each IDI.
The modified approach also places greater focus on engagement and capabilities testing by FDIC staff. This structured, periodic engagement will be used to seek further understanding of content submitted in the plan and to assess a filer’s ability to produce relevant information.
Each filer covered under the statement will receive a letter from the FDIC that specifies exempted plan content and the due date for the next filing. Resolution plans will be submitted in two groups, with the first group consisting of IDIs whose top tier parent company is not a U.S. global systemically important bank or a category II banking organization. The second group will be all other IDIs with $100 billion or more in total assets. For institutions with less than $100 billion in total assets, the moratorium on submission of IDI plans announced in November 2018 remains in effect.