BPI Recommends Changes to the FDIC’s Requirement that Insured Banks Submit Resolution Plans

BPI filed a comment letter with the FDIC concerning its requirement that all insured banks with $50 billion or more of assets file a plan each year detailing how they would be resolved under the FDI Act (a so-called “IDI plan”). The letter was in response to a notice that the FDIC ran in the Federal Register to renew the information collection elements of the IDI plan requirement. BPI took the opportunity to make two key recommendations to the FDIC. One, the FDIC staff should provide guidance about its expectations for IDI plans on a public rather than confidential basis to enhance transparency in the process. And two, the informational requirements for IDI plans, on the one hand, and holding company bankruptcy plans required under Section 165(d) of Dodd-Frank, on the other hand, should be harmonized, allowing filers to focus their resolution planning efforts on a single resolution plan filing containing information and analysis that is most applicable to their business model and risk profile while also lowering the burden of review by agency staff. BPI believes that implementing these changes will improve the usefulness of the information collected in the IDI plan and minimize the associated burden on filers.