Financial Institutions Advisory & Financial Regulatory counsel Gregg Rozansky (New York) was quoted by International Financial Law Review (IFLR) in an article on the approval by the Federal Deposit Insurance Corporation of the so-called "living wills" rule intended to reduce systemic risks posed by the failure of large financial groups.

Rozansky provided insight on changes made to the rule since it was originally proposed in March of this year. Commenting on banks' reception of a more lenient filing timeline for certain non-U.S. headquartered institutions with limited U.S. operations, Rozansky said, "This gives them a lot more breathing room than they initially thought they would have [based on the proposed rules issued last Spring]." He also highlighted additional guidance in the area of alternate resolution scenarios as meaningful, adding, "This clarification was a helpful change."

Rozansky went on to advise that the FDIC's version of the rule could still see further changes, noting, "Since the Federal Reserve has not yet formally approved this, we can't rule out the possibility of further changes." He added, "The Federal Reserve is traditionally highly attuned to the concerns of the international banking community." Rozansky further advised, "Until the Fed signs off, the dust has not completely settled."