The Clearing House Association filed a comment letter with the FDIC and Fed on their proposal implementing resolution planning and credit-exposure reports. The letter advocates for, among other things, a phasing in of the proposed rule, a pilot program, a more iterative and supervisory process, international coordination and greater confidentiality standards. At its September 13 meeting, the FDIC Board approved a rule on the living wills required by § 165(d)(1) of Dodd-Frank. Key features of the § 165 Rule include several changes from the proposed version, as advocated by TCH: (i) an iterative process actively involving dialogue between firms and regulators, (ii) phasing in the implementation of the submission deadlines, starting with the largest firms, which will have to submit their resolution plans by July 2012, (iii) a requirement, upon a material change, to give notice to the agency (rather than to submit an updated plan), (iv) postponement of final rulemaking on credit-exposure reports to allow further coordination with FRB actions, and (v) greater confidentiality protections. In addition, as TCH recommended in its related comment letter, the FDIC has harmonized the IDI Rule with the § 165 Rule, so that, for example, timing and content requirements are more consistent and duplicative effort is limited.