On March 15, the FDIC approved a Notice of Proposed Rulemaking to clarify application of the orderly liquidation authority mandated by the Dodd-Frank Act. The NPR: (i) builds on the interim rule of January 18, which clarified certain issues under the OLA; (ii) establishes a framework for the priority payment of creditors and for the procedures for filing a claim with a receiver and, if dissatisfied, pursuing a claim in court; (iii) clarifies how compensation will be recouped from senior executives and directors who are substantially responsible for the failure of the firm; and (iv) clarifies the meaning of "financial company". Comments must be submitted within 60 days after publication in the Federal Register. FDIC Release. FDIC Proposed Rule.