Key Takeaways from FDIC Guidance for Bank Resolution Plans

On December 17, 2014, the Federal Deposit Insurance Corporation released its most detailed guidance to date on resolution plan requirements for insured depository institutions with $50 billion or more in total assets. The Guidance effectively seeks a detailed plan that could be implemented as a playbook to resolve the bank. The Guidance seeks to accomplish this by mandating a much greater level of detailed analytical support for assumptions, scenarios, strategies, and related operational details than has been required previously. The FDIC will apply the Guidance to plans filed in 2015.

While the Guidance builds on prior FDIC feedback, its additional requirements will increase the cost and complications of preparing CIDI resolution plans.