Your 10-K is not the place for a lesson in administrative law

Before

The FDIC announced on April 13, 2010, its Board of Directors’ approval of a Notice of Proposed Rulemaking on Assessments. The proposed revisions to the assessment system would be applicable to large institutions with more than $10 billion in assets, such as ABC Bank. According to the FDIC, the proposed revisions would better capture risk at the time an institution assumes the risk, better differentiate institutions during periods of good economic and banking conditions based on how they would fare during periods of stress or economic downturns, and would also take into account the losses that the FDIC may incur if an institution fails. The proposal was published in the Federal Register on May 3, 2010, and the comment period for the proposal expired on July 2, 2010.

Before, with commentary

The FDIC announced on April 13, 2010, its Board of Directors’ approval of a Notice of Proposed Rulemaking on Assessments [people may care what the proposed rules cover, but they are unlikely to care about the process]. The proposed revisions to the assessment system would be applicable to large institutions with more than $10 billion in assets, such as ABC Bank. According to the FDIC, the proposed revisions would better capture risk at the time an institution assumes the risk, better differentiate institutions during periods of good economic and banking conditions based on how they would fare during periods of stress or economic downturns, and would also take into account the losses that the FDIC may incur if an institution fails. The proposal was published in the Federal Register on May 3, 2010 [most of your non-lawyer readers have no idea what the Federal Register is and why publication in the Federal Register is important], and the comment period [they aren’t familiar with the comment period either] for the proposal expired on July 2, 2010.

[For the record, I am not saying your readers are dumb. I am just saying that they don’t care about the process for adopting a federal rule. Just tell them what the proposal is and how it might affect you.]

After

On April 13, 2010, the FDIC announced proposed revisions to the assessment system for institutions with more than $10 billion in assets, such as ABC Bank. According to the FDIC, the proposed revisions would better capture risk at the time an institution assumes the risk, better differentiate institutions during periods of good economic and banking conditions based on how they would fare during periods of stress or economic downturns, and also would take into account the losses the FDIC may incur if an institution fails. The FDIC accepted public comments on the proposal until July 2, 2010, but has not adopted any final rules.