BPI Comments on Advance Notice of Proposed Rulemaking on Resolution-related Resource Requirements for Large Banks

Dear Ms. Misback, Mr. Sheesley:

The Bank Policy Institute (BPI)[1] submit this letter in response to the October 24, 2022, advance
notice of proposed rulemaking of the Board of Governors of the Federal Reserve System (Federal Reserve) and the Federal Deposit Insurance Corporation (FDIC and together with the Federal Reserve, the Agencies) “regarding whether an extra layer of loss-absorbing capacity could improve optionality in resolving a large banking organization or its insured depository institution, and the costs and benefits of such a requirement.”[2]

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[1]The Bank Policy Institute is a nonpartisan public policy, research and advocacy group, representing the nation’s leading banks. Our members include universal banks, regional banks and the major foreign banks doing business in the United States. Collectively, they employ nearly 2 million Americans, make nearly half of the nation’s bank-originated small business loans and are an engine for financial innovation and economic growth.

[2] Federal Reserve and FDIC, Resolution-Related Resource Requirements for Large Banking Organizations, 87 Fed. Reg. 64,170, 64,170 (Oct. 24, 2022) (ANPR).