Key Takeaways 

• The FDIC has taken the next step in implementing the Orderly Liquidation Authority under Title II by proposing an additional rule. 
• The proposed rule provides additional details on such areas as the priority of claims, the administrative claims process, the process for judicial determination of claims, and the treatment of secured claims. 
• The proposed rule establishes additional rules to implement the special authority to recoup compensation paid to senior executives and directors of a financial company that becomes subject to an orderly liquidation.