BPI Response to FDIC Resolution Plans Required for Insured Depository Institutions With $100 Billion or More in Total Assets

Ladies and Gentlemen:

The Bank Policy Institute [1] submits these comments in response to the Federal Deposit Insurance Corporation’s proposal entitled Resolution Plans Required for Insured Depository Institutions With $100 Billion or More in Total Assets; Informational Filings Required for Insured Depository Institutions With at Least $50 Billion But Less Than $100 Billion in Total Assets.[2]

I. Executive Summary

If adopted as proposed, the proposal would mark a significant shift in how covered insured depository institutions (CIDIs) [3] approach resolution submissions under 12 C.F.R. Part 360 (the IDI Rule). While it is understandable that the FDIC would want to address lessons learned from the March 2023 banking turmoil, the result has been to overload the IDI Rule with entirely new or heightened requirements that, in some cases, are unnecessary to achieve the goal of improving the resolvability of CIDIs, and, in other cases, may actively hinder that goal. The alternatives proposed in these comments aim to streamline the proposal and to make the resolution planning process more efficient and effective. These improvements will help CIDIs that are subject to the IDI Rule provide the information necessary to facilitate resolutions, while also having the time and resources to enhance operational capabilities and respond to feedback.

Our comments proceed as follows:

  • Section II addresses the form and timing of resolution planning submissions;
  • Section III addresses revisions or additions to the content requirements under the proposal;
  • Section IV addresses the requirements for capabilities testing and engagement; and
  • Section V addresses the proposed assessment criteria for CIDIs’ IDI plan submissions and related processes.

To read the full comment letter, please click here, or click on the download button below.


[1] BPI is a nonpartisan public policy, research and advocacy group, representing the nation’s leading banks and their customers. BPI’s members include universal banks, regional banks and major foreign banks doing business in the United States.

[2] FDIC, Resolution Plans Required for Insured Depository Institutions With $100 Billion or More in Total Assets; Informational Filings Required for Insured Depository Institutions With at Least $50 Billion But Less Than $100 Billion in Total Assets, 88 Fed. Reg. 64579 (Sept. 19, 2023), https://www.govinfo.gov/content/pkg/FR-2023-09-19/pdf/2023-19266.pdf.

[3] Under the proposal, CIDIs would be divided into two groups that would be subject to different filing requirements, depending on size. CIDIs with total assets of $100 billion or more (Group A CIDIs) would be required to submit a full IDI plan containing all content elements described in the proposal, and CIDIs with total assets of at least $50 billion and less than $100 billion (Group B CIDIs) would be required to make an informational filing. As a general matter, we refer to resolution plans submitted by Group A and Group B CIDIs as IDI plans throughout this letter.