Prior to the recent crisis, the Federal Deposit Insurace Company’s receivership authority was limited to federally insured banks and thrift institutions. There was no authority to place the holding company or affiliates of an insured institution or any other nonbank financial company into an FDIC receivership to avoid systemic consequences. The lack of this authority severely constrained the ability of the government to resolve a systemically important financial institution. This authority has now been provided to the FDIC under the Dodd–Frank Act.

The question is whether the FDIC can develop the operational capability to utilize this authority effectively and a credible strategy under which an orderly resolution of a SIFI can be carried out without putting the financial system itself at risk. These key challenges have been the focus of the FDIC’s efforts since the enactment of Dodd–Frank in July 2010.