In this report, we evaluate the FDIC’s proposal to refine the orderly-liquidation authority (OLA) process for systemic institutions mandated by the Dodd-Frank Act.  It throws the risk-retention rule into the same quandary as the FDIC’s earlier rule did for bank receiverships regarding ABS issued by insured depositories.  We also note a provision in the FDIC’s new systemic-resolution procedures that sticks it to Fannie Mae, Freddie Mac and the FHLBs if a counterparty goes bust.

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