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Inside Washington (10/17/2011)
* WASHINGTON (10/18/11)--The Federal Reserve Board on Monday released the final rule to implement the resolution plan requirement in the Dodd-Frank Wall Street Reform and Consumer Protection Act. The final rule requires bank holding companies with assets of $50 billion or more and nonbank financial firms designated by the Financial Stability Oversight Council for supervision to annually submit resolution plans. Each plan will describe the company’s strategy for resolution in bankruptcy in case of financial distress. A resolution plan must include a strategic analysis of the plan’s components, specific actions the company proposes to take in resolution, and a description of the company’s organizational structure, material entities, interconnections and interdependencies, and management information systems. Under the final rule, companies will submit their initial resolution plans on a staggered basis. The first group of companies, those with $250 billion or more in non-bank assets, must submit their initial plans on or before July 1, 2012; the second group, those with $100 billion or more but less than $250 billion in total non-bank assets, must submit their initial plans on or before July 1, 2013; and the remaining companies, those with less than $100 billion in total non-bank assets, must submit their plans on or before Dec. 31, 2013 …


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