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Holding
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The FDIC is issuing a final rule (``Final Rule'') that treats a mutual insurance holding company as an insurance company for purposes of Section 203(e) of the Dodd-Frank Wall Street Reform and Consumer Protection Act (the ``Dodd-Frank Act''). The Final Rule clarifies that the liquidation and rehabilitation of a covered financial company that is a mutual insurance holding company will be conducted in the same manner as an insurance company. The Final Rule harmonizes the treatment of mutual insurance holding companies under Section 203(e) of the Dodd- Frank Act with the treatment of such companies under state insurance company insolvency laws.
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As demand increases, most of the largest regional legal departments are growing or keeping a steady headcount of attorneys. Companies are holding fast to their in-house talent, judging by the number of attorneys listed in Missouri Lawyers Weekly's directory of in-house counsel and ranking of the 29 largest in- house departments in the region. The attorney listings increased at 12 of the largest 26 in-house departments for which two years of information was available. The listings stayed the same at seven other companies, with the remainder showing decreases.
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The FDIC is proposing a rule (``Proposed Rule''), with request for comments, that provides for the treatment of a mutual insurance holding company as an insurance company for the purpose of Section 203(e) of the Dodd-Frank Wall Street Reform and Consumer Protection Act (the ``Dodd-Frank Act''), 12 U.S.C. 5383(e). The Proposed Rule clarifies that the liquidation and rehabilitation of a covered financial company that is a mutual insurance holding company will be conducted in the same manner as an insurance company. The Proposed Rule is intended to harmonize the treatment of mutual insurance holding companies under Section 203(e) of the Dodd-Frank Act with the treatment of such companies under state insolvency regimes.
