SIFMA provides comments to the Federal Deposit Insurance Corporation (FDIC) on the interim final rule implementing certain orderly liquidation authority provisions of the Dodd-Frank Wall Street Reform and Consumer Protection Act (Dodd-Frank Act).  SIFMA filed letters with the FDIC during the 30-day comment period and the 60-day comment period on the proposal.  SIFMA believes in order for this new authority to work properly, the FDIC will need to issue rules and regulations that convince the market that Title II of the Dodd-Frank Act will be exercised in a consistent, transparent and predictable manner that strikes the right balance among preserving or restoring financial stability, maximizing the value of the enterprise, minimizing shareholder and creditor losses, preserving equal treatment among similarly situated creditors and maximizing market discipline.