The Federal Reserve Board ("FRB") and FDIC final rule amending resolution planning requirements under the Dodd-Frank Act was published in the Federal Register. The final rule is effective on December 31, 2019.

As previously covered, the final rule is designed to make improvements to the November 2011 joint resolution plan rule and implement amendments made by the Economic Growth, Regulatory Relief and Consumer Protection Act. Pursuant to the final rule, both agencies will extend the "default resolution plan filing cycle" and permit more focused resolution plan submissions. Additionally, the FRB will tailor the resolution planning requirements to U.S. and foreign banking organizations by using four "risk-based categories." The final rule would allow only smaller and less complex firms to request waivers of particular elements of their full resolution plans. If such requests are submitted, those firms will have to receive approval from both the FRB and the FDIC.