Bankruptcy and Insolvency

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OCC-supervised institutions with $100 billion or more in average total consolidated assets must be adequately prepared to mitigate severe financial and non-financial risks.

By Arthur S. Long, Pia Naib, and Deric Behar

On July 3, 2024, the Office of the Comptroller of the Currency (OCC) issued a proposal (the Proposal) to revise its enforceable recovery planning guidelines1 (the Guidelines) for certain large insured national banks, insured federal savings associations, and insured federal branches of non-US banks (together…

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Insured depository institutions with $50 billion to less than $100 billion in average total assets are subject to new resolution reporting standards, with enhanced reporting for those with average total assets of $100 billion or more.

By Arthur S. Long, Pia Naib, and Deric Behar

On June 20, 2024, the Federal Deposit Insurance Corporation (FDIC) issued a final rule (the Rule) updating the FDIC’s resolution plan regulations1 for covered insured depository institutions (CIDIs).2 The revisions are…