The FDIC’s Orderly Liquidation Authority

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Date Issued

Thursday, September 28, 2023

Submitting OIG

Federal Deposit Insurance Corporation OIG

Other Participating OIGs

Federal Deposit Insurance Corporation OIG

Agencies Reviewed/Investigated

Federal Deposit Insurance Corporation

Report Number

EVAL-23-004

Report Type

Inspection / Evaluation

Agency Wide

Yes

Number of Recommendations

Questioned Costs

Funds for Better Use

Open Recommendations

This report has 8 open recommendations.

Recommendation Number	Significant Recommendation	Recommended Questioned Costs	Recommended Funds for Better Use
2	No	$0	$0
Develop and consistently maintain comprehensive Orderly Liquidation Authority policies and procedures for systemically important financial companies, to include:a. Tier I policies and procedures for framework-level activities.b. Tier II policies and procedures for operational process-level activities.c. Tier III policies and procedures for institution-specific planning activities.d. Other operational program policies and procedures for Orderly Liquidation Authority resolution planning activities.
3	No	$0	$0
Develop and consistently maintain comprehensive Orderly Liquidation Authority policies and procedures for systemically important financial companies, to include:a. Tier I policies and procedures for framework-level activities.b. Tier II policies and procedures for operational process-level activities.c. Tier III policies and procedures for institution-specific planning activities.d. Other operational program policies and procedures for Orderly Liquidation Authority resolution planning activities.
6	No	$0	$0
Establish a process for identifying and preparing staff who would be responsible for key Orderly Liquidation Authority resolution governance roles, such as the Executive Advisory and Oversight Group, the Tactical Project Manager, and the Onsite Liaison, to include:a. Completing planned guidance and/or preparing a charter that will define in more detail the key resolution governance roles and responsibilities.b. Maintaining a roster of potential staff for key resolution governance roles.c. Informing potential staff for the key resolution governance roles of their respective Orderly Liquidation Authority resolution responsibilities.
7	No	$0	$0
Ensure the completed Tier I and II policies, procedures, and related guidance documents fully define the applicable Orderly Liquidation Authority roles and responsibilities of each FDIC Division and Office.
8	No	$0	$0
Ensure the FDIC establishes a timeframe to obtain, and then obtains, the staff resources needed to mature the Orderly Liquidation Authority resolution planning program.
9	No	$0	$0
Conduct and document a representative survey or other assessment of the Orderly Liquidation Authority-related skill sets existing or needed within the Division of Complex Institution Supervision and Resolution and ensure the Division’s Professional Development Plan incorporates the results.
11	No	$0	$0
Regularly conduct and document Orderly Liquidation Authority general and functional training and ensure that training is clearly linked to the key components of the systemic resolution framework and processes.
17	No	$0	$0
Develop an FDIC readiness plan for a financial crisis, to include a scenario that involves the resolution of multiple concurrent failures of systemically important financial companies.