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The FDIC announced initial submission dates for its final rule requiring resolutions plans for banks with at least $100 billion in assets and “informational filings” for banks over $50 billion.
Background: Under the final rule, which takes effect Oct. 1, banks between $50 billion and $100 billion must submit informational filings, which do not include resolution strategies and related valuation information, to assist in their potential resolution.
What’s New: The FDIC announced five cohorts with reporting deadlines in 2025 and 2026.
ICBA Comments: In a comment letter to the FDIC last fall, ICBA said it agrees with resolution planning for banks with at least $100 billion in assets, but banks between $50 billion and $100 billon should generally be exempt.