At its final meeting under the direction of Chairman Sheila Bair, the FDIC board focused on finalizing rules for orderly liquidation authority (“OLA”) and resolution plans both as mandated under the Dodd-Frank Act and as applicable under the FDIC’s sole authority for insured depositories.  Reflecting both the complexity and controversy related to these resolution plans, action on the rules was deferred despite Ms. Bair’s previously-expressed hope that the systemic living-will standard would be one of her final, hallmark achievements.  The final OLA rule is another in the continuum of FDIC actions establishing procedures for shuttering systemic firms.  This rule was revised in part to limit its reach to senior executives, satisfying a concern of OCC Acting Comptroller Walsh.  Detailed reports on the OLA final rule will shortly be provided to clients, along with FedFin assessments of the new standards approved by the FDIC on retail foreign-exchange products and interest-bearing business demand accounts once other agencies advance these important requirements.  All of this action is analyzed in this report.

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