ABA Comment Letter - FDIC Orderly Liquidation Authority

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The FDIC proposal would implement its Orderly Liquidation Authority (OLA) to resolve covered financial companies under Title II of the Dodd-Frank Act of 2010. The FDIC issued the rule to provide greater clarity and certainty to the banking, insurance, and securities industries that would likely be subject to the new bankruptcy regime. Under the rule, the FDIC would manage the liquidation of failing non-bank financial companies and bank holding companies of sufficient size and complexity.

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DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

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