In September 2011 the Federal Reserve Board and the Federal Deposit Insurance Corporation issued a final rule under Dodd-Frank that required bank holding companies with assets of $50 billion or more and companies designated as systemically important by the Financial Stability Oversight Counsel, a “covered company,” to submit to the Fed, FDIC and the oversight counsel a resolution plan for resolution under the Bankruptcy Code in the event of material distress or failure.
In January 2012 the FDIC also issued a final rule (IDI Rule) that required insured depository institutions with assets of $50 billion or more to submit to the FDIC a plan for resolution in the event of failure under the Federal Deposit Insurance Act. The initial submissions under the two rules were due on July 1, 2012.
