The Federal Deposit Insurance Corporation (“FDIC”) recently approved a proposed rule, developed jointly with the Federal Reserve Board (“Fed”) (together, the “Agencies”) that would implement Section 165(d) of the Dodd-Frank Wall Street Reform and Consumer Protection Act (the “Dodd-Frank Act”) and require bank holding companies (“BHCs”) with total consolidated assets of $50 billion or more and nonbank financial companies supervised by the Fed (collectively, “Covered Companies”) to submit to the Agencies: