On December 17, 2014, the Federal Deposit Insurance Corporation (“FDIC”) issued guidance for resolution plans which must be submitted by insured depositary institutions with assets greater than $50 billion (“Covered  Institutions”). FDIC rules require Covered Institutions to provide a resolution plan that will permit the FDIC as receiver under the Federal Deposit Insurance Act to resolve the institution in a methodical manner. The plan should allow for prompt access of insured deposits, maximization of the return from the failed institution’s asset, and mitigation of losses realized by creditors. The FDIC guidance includes direction on the fundamentals that should be introduced in a fully developed resolution strategy. The guidance entails a cost analysis, clarification regarding assumptions made in the plan, and a list of significant complications that institutions should address. The guidance relates to the resolution plans of

36 insured banks that currently meet the criteria, as well as any new institution meeting the threshold, commencing with the 2015 submissions.

The guidance is available at: