The FDIC today published the initial submission dates for certain banks to file resolution plans under new requirements adopted in June. Under the new rule, banks with at least $100 billion in assets must submit a strategy that describes their resolution from the point of failure through the sale or disposition of the franchise. Banks with at least $50 billion in assets are required to submit information filings that do not need to be as detailed as the plans submitted by larger banks.
The FDIC published a list of banks along with the dates they must file their plans. Banks over $100 billion are divided into three “cohorts” with different filing dates. Banks over $50 billion are divided into two cohorts with filing dates.
