• Dodd-Frank, FDIC and FSA Rules Require Financial Companies to Develop Global Insolvency Contingency Plans
  • September 27, 2011 | Authors: Jay M. Goffman; Christopher Mallon; Mark A. McDermott; William J. Sweet; David M. Turetsky
  • Law Firms: Skadden, Arps, Slate, Meagher & Flom LLP - New York Office ; Skadden, Arps, Slate, Meagher & Flom LLP - London Office ; Skadden, Arps, Slate, Meagher & Flom LLP - New York Office ; Skadden, Arps, Slate, Meagher & Flom LLP - Washington Office ; Skadden, Arps, Slate, Meagher & Flom LLP - New York Office
  • On September 13, 2011, the Federal Deposit Insurance Corporation (FDIC) approved a rule that requires large bank holding companies and other systemically important financial companies to develop comprehensive contingency plans for the orderly resolution of their affairs under the United States Bankruptcy Code or other applicable insolvency regime (Dodd-Frank Rule). The Dodd-Frank Rule has been forwarded to the Federal Reserve Board (Board) for its review and approval. It is anticipated that the Board likely will approve the rule in the near term, at which time the rule will become law, subject to such change as the Board and FDIC may agree.