On October 17, the Fed and the FDIC adopted a final rule to implement the resolution plan requirement of Section 165(d)(1) of the Dodd-Frank Act.  Companies with $250 billion or more in non-bank assets will be required to submit an initial plan by July 1, 2012; companies with non-bank assets ranging from $100-$250 billion must submit an initial plan by July 1, 2013; and companies subject to the rule with less than $100 billion in non-bank assets must submit an initial plan by December 31, 2013.  The rule will be effective on November 30.  Joint Release Final Rule.