On September 13, 2011, the Federal Deposit Insurance Corporation (the "FDIC") approved a final rule (the "Final Rules") to be issued jointly by the FDIC and the Board of Governors of the Federal Reserve System (the "Board") intended to implement section 165(d) of the Dodd-Frank Wall Street Reform and Consumer Protection Act (the "Dodd-Frank Act") which requires each non-bank financial company supervised by the Board and each bank holding company with assets of US$50 billion or more (each, a "Covered Company") to report periodically to the Board, the FDIC and the Financial Stability Oversight Council (the "Council") the plan of such company for rapid and orderly resolution in the event of material financial distress or failure (a "Resolution Plan"). The Final Rules were issued simultaneously with the approval by the FDIC's board of directors of a rule that would require insured depository institutions with US$50 billion or more in total assets to submit periodic contingency plans to the FDIC in the event of the depository institution failure.

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