Financial Services Forum Urges FDIC to Recognize Existing Resolution Capabilities of U.S. GSIBs

Financial Services Forum Urges FDIC to Recognize Existing Resolution Capabilities of U.S. GSIBs

Washington, D.C. - The Financial Services Forum today submitted comments on the Federal Deposit Insurance Corporation's (FDIC) proposed rules concerning resolution submissions for covered insured depository institutions and assessments, thresholds, rate schedules, and adjustments.

The Forum supports the FDIC's effort to create a workable resolution framework that facilitates the efficient and effective resolution of depository institutions. The Forum believes, however, that the proposals do not sufficiently recognize the important differences in the resolution framework for entities that have adopted a single-point-of entry (SPOE) resolution strategy under Title I of the Dodd-Frank Act (Title I SPOE Filer). These important differences render key aspects of the FDIC's proposals either duplicative or unnecessary. All Forum members are Title I SPOE Filers and the proposal's failure to recognize the significant differences in the resolution framework for Title I SPOE Filers is highly problematic.

The Forum's comments make three specific points in this regard.

First, Title I SPOE Filers should not be required to file covered insured depository institution (CIDI) resolution submissions. In particular, the CIDI requirements are wholly inconsistent with the SPOE resolution framework in which the depository institution does not enter FDIC receivership or conservatorship.

Second, the proposed data access component of the resolution readiness adjustment (RRA) is not appropriate for Title I SPOE Filers. Because Title I resolution plans already provide the FDIC with extensive information about the depository institution, the final rules should recognize the existing Title I resolution plans and capabilities rather than impose separate data access requirements.

Third, existing Title I virtual data room (VDR) capabilities should fully satisfy the RRA for Title I SPOE Filers. The proposal's data access requirements would provide limited incremental resolution benefit beyond the information and rapid-production capabilities already available through the existing Title I and VDR frameworks. Further, extending access to the highly sensitive and interconnected systems would raise unnecessary and additional cybersecurity, confidentiality, operational, and third-party risk-management concerns.

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The Financial Services Forum is an economic policy and advocacy organization whose members are the eight largest and most diversified financial institutions headquartered in the United States. Forum member institutions are a leading source of lending and investment in the United States and serve millions of consumers, businesses, investors, and communities throughout the country. The Forum promotes policies that support savings and investment, financial inclusion, deep and liquid capital markets, a competitive global marketplace, and a sound financial system.

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