Client Alert

| October 24, 2011

The Federal Reserve Board Modifies Requirements for Resolution Plans

On October 18, 2011 the Federal Reserve Board, together with the Federal Deposit Insurance Corporation (the “FDIC”), released the final rule implementing the requirement in section 165(d) of the Dodd-Frank Wall Street Reform and Consumer Protection Act that certain financial companies prepare so-called resolution plans or “living wills.” These plans are intended to help the Federal Reserve, the FDIC and the Financial Stability Oversight Council better respond to the financial distress of a systemically important financial company and to some types of instability in the financial system itself.

This memorandum is intended only as a general discussion of these issues. It is not considered to be legal advice. We would be pleased to provide additional details or advice about specific situations. For additional information on this important topic, please feel free to call upon your Dewey & LeBoeuf relationship partner. No part of this publication may be reproduced, in whole or in part, in any form, without our prior written consent. For further information on Dewey & LeBoeuf, please visit www.dl.com. +1 888 532 6383