FDIC to Meet Next Week on a Number of Proposals

Cadwalader, Wickersham & Taft LLP

Cadwalader, Wickersham & Taft LLP

The Federal Deposit Insurance Corporation (“FDIC”) gave notice that its Board of Directors will meet next week with the following discussion agenda:

  • Memorandum and resolution re: Notice of Proposed Rulemaking on Long-term Debt Requirements for Large Bank Holding Companies, Certain Intermediate Holding Companies of Foreign Banking Organizations, and Large Insured Depository Institutions.
  • Memorandum and resolution re: Resolution Plans Required for Insured Depository Institutions with $100 Billion or More in Total Assets; Informational Filings Required for Insured Depository Institutions with At Least $50 Billion, but Less Than $100 Billion in Total Assets.
  • Memorandum and resolution re: Publication of Proposed Guidance for Dodd-Frank Act Resolution Plan Submissions of Triennial Full Filers.
  • Memorandum and resolution re: Conditions to Certain Receivership Delegations of Authority and Procedures.
  • Memorandum and resolution re: Board Approval of Midsized and Large Failed Bank Sales.

The headlines for this meeting certainly are the consideration of proposals to require long-term debt for large bank holding companies (“BHCs”), and requiring resolution plans for insured depository institutions (“IDIs”) with $100 billion or more in assets. As we covered in last week’s newsletter, FDIC Chair Gruenberg said such proposals would be coming “soon” and so, in this case, soon means about two weeks. Expanding the long-term debt requirement to large BHCs will likely be an interagency rule with the Federal Reserve Board and the Office of the Comptroller of the Currency. The expansion of the IDI resolution plans is solely in the FDIC’s jurisdiction.

We will likely have a look at what comes out of the meeting in next week’s newsletter.          

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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