Doc of the Day: Living Wills: The Final Rule — A User Guide

Morrison & Foerster’s comprehensive guide to the FDIC living wills rule:

“With a final rule recently approved by the Federal Reserve Board of Governors (‘FRB’) and the Federal Deposit Insurance Corporation (‘FDIC’), and a related interim rule applying to covered insured depository institutions, every covered company, U.S. and worldwide, should now begin its early-stage resolution plan process. For a number of covered companies, this will involve submitting a resolution plan, or ‘living will,’ for the organization as a whole, as well as a separate resolution plan for its covered insured depository institution(s). For all covered companies, this process involves a significant amount of internal organization and coordination, including participation by the board of directors and highest levels of management.We have designed these materials with three principal objectives:1. To provide a high-level summary of the fundamental and most pressing issues covered companies are now facing;2. To suggest ways to streamline early-stage planning; and3. To discuss the practical implications of resolution planning, including useful background analyses and related regulatory requirements.”

Read the full update hereSee also:Dodd-Frank Update: FDIC Final Rule for “Living Wills” LegalMinds/NASDAQ Interview Transcript: Dodd-Frank’s “Living Will Rule” and the Impact on Financial Firms – Walter Mix III, Director, Berkeley Research Group (Bruce Colwin)Living Will Requirements Come into Focus (Dechert LLP) Banking Industry Regulatory Update – September 2011 (Reed Smith) FSOC Issues New Proposed SIFI Designation Rule (Dechert LLP)