• Service: Audit, Tax, Advisory
  • Industry: High Growth Markets, Insurance, Banking & Capital Markets
  • Type: Publication series
  • Date: 8/23/2012

Risk Resolution Plans Filed: A Brief Overview of June 2012 Living Will Filings 

The FDIC adopted a final rule to implement the requirements outlined in section 165 of Dodd-Frank regarding resolution plans. This rule requires an insured depository institution with $50 billion or more in total assets to submit periodically to the FDIC a contingent plan for the resolution of such institution in the event of its failure (“Resolution Plan”).

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The Rule establishes the requirements for submission and content of a Resolution Plan, as well as procedures for review by the FDIC. The plans will supplement the FDIC’s own resolution planning work with information that would help facilitate an orderly resolution in the event of failure.


There are a projected 120 institutions that are listed as systemically important and will have a financial impact if they fail; these institutions must submit a risk resolution plan that would avoid major disruptions.


The first wave of filings has been made public as of July 2, 2012. This overview outlines which companies filed and key factors released by the FDIC.