On September 28, BPI submitted a comment letter to the FDIC concerning the proposal to renew the Insured Depository Institution (“IDI”) Rule’s information collection requirement. The letter, which was submitted jointly with SIFMA, recommends that FDIC staff provide forward-looking guidance on IDI Plan requirements, and suggests the harmonization of information requirements for IDI Plans and 165(d) Plans. Implementing these changes to the IDI Plan, the letter argues, will improve the information collected pursuant to the Rule and minimize the association burden on filers.
