On June 20, 2024, the Federal Deposit Insurance Corporation (“FDIC”) issued a final rule comprehensively restating and expanding its resolution planning rule (the “IDI Rule”) applicable to large insured depository institutions (“IDIs”).[1]  The release finalizes the rule proposal from August 29, 2023 (the “Proposal”). The Proposal was released alongside (i) proposed guidance on resolution planning for section 165(d) holding company…

In a speech on May 27, 2024, Acting Comptroller of the Currency, Michael J. Hsu, stated that expanding the application of the Office of the Comptroller of the Currency’s (“OCC”) recovery guidelines (the “Recovery Guidelines”) to all large banks under OCC oversight (i.e., national banks, federal savings banks and federal branches) with at least $100 billion in assets “warrants serious…

As detailed in our recent Debevoise in Depth articles,[1] both the Office for the Comptroller of the Currency (“OCC”) and the Federal Deposit Insurance Cooperation (“FDIC”) have proposed changes to their Bank Merger Act (“BMA”) review policies, with the FDIC also proposing updates to its supplemental BMA application form.[2]  As to the Federal Reserve Board (“FRB”), at an April 10,…

Introduction On April 10, 2024, the Federal Deposit Insurance Corporation (the “FDIC”) released a report regarding Title II of the Dodd-Frank Wall Street Reform and Consumer Protection Act (the “Dodd-Frank Act“),[1] titled Overview of Resolution Under Title II of the Dodd-Frank Act (the “Report”).[2] Enacted in 2010, in response to the 2008 financial crisis, Title II of the Dodd-Frank Act…

Hundreds of hours’ worth of changes and additions proposed for applicants On March 21, 2024, the Federal Deposit Insurance Corporation (“FDIC”) published a proposed update to its Statement of Policy on Bank Merger Transactions, detailed in our March 27, 2024 Debevoise In Depth.[1]  As previewed in that proposal, on April 19, 2024, the FDIC proposed an update to its Supplement…