Ladies and Gentlemen:
The Bank Policy Institute, the American Bankers Association, the Financial Services Forum, the Institute of International Bankers, and the Securities Industry and Financial Markets Association[1] submit this letter requesting a 60-day extension of the comment period for each of 1 See Appendix for information on the associations. the following four resolution-related proposals (together, the Resolution-Related Proposals):
- Long-Term Debt Requirements for Large Bank Holding Companies, Certain Intermediate Holding Companies of Foreign Banking Organizations, and Large Insured Depository Institutions (Long-Term Debt Proposal); [2]
- 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 (IDI Rule Proposal);[3]
- Guidance for Resolution Plan Submissions of Domestic Triennial Full Filers (Domestic Filer Proposed Guidance); and [4]
- Guidance for Resolution Plan Submissions of Foreign Triennial Full Filers (Foreign Filer Proposed Guidance and, together with the Domestic Filer Guidance, 165(d) Proposed Guidance).[5]
We are requesting extensions given the extent to which the four proposals relate to one another, as well as to the currently open Basel III Endgame Proposal [6] and, for several banking organizations, the GSIB Surcharge Proposal.[7] Specifically, we believe that comment period extensions are appropriate because:
- the number, length, and complexity of the proposals require detailed attention from affected banking organizations;
- understanding certain of the effects of the proposals requires analysis and understanding of the potential effects of other proposals;
- comments on one proposal may relate to or affect comments on another proposal; and
- the same personnel from affected banking organizations are, in many cases, responsible for analyzing the proposals.
These factors all argue in favor of extending the comment periods for each of the Resolution Related Proposals so that banking organizations have sufficient time and resources to evaluate the content of each proposal, as well as how they interact with one another. Accordingly, we request a 60-day extension of the comment periods for each of the Resolution-Related Proposals, until January 30, 2024, or until the date that is 60 days following the end of the comment period for the Basel III Endgame Proposal, whichever is later.
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[1] See Appendix for information on the associations.
[2] Board of Governors of the Federal Reserve System, Federal Deposit Insurance Corporation, Office of the Comptroller of the Currency, Long-Term Debt Requirements for Large Bank Holding Companies, Certain Intermediate Holding Companies of Foreign Banking Organizations, and Large Insured Depository Institutions, 88 Fed. Reg. 64524 (Sept. 19, 2023).
[3] Federal Deposit Insurance Corporation, 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).
[4] Board of Governors of the Federal Reserve System, Federal Deposit Insurance Corporation, Guidance for Resolution Plan Submissions of Domestic Triennial Full Filers, 88 Fed. Reg. 64626 (Sept. 19, 2023).
[5] Board of Governors of the Federal Reserve System, Federal Deposit Insurance Corporation, Guidance for Resolution Plan Submissions of Foreign Triennial Full Filers, 88 Fed. Reg. 64641 (Sept. 19, 2023).
[6] Board of Governors of the Federal Reserve System, Federal Deposit Insurance Corporation, Office of the Comptroller of the Currency, Regulatory Capital Rule: Large Banking Organizations and Banking Organizations With Significant Trading Activity, 88 Fed. Reg. 64028 (Sept. 18, 2023).
[7] Board of Governors of the Federal Reserve System, Regulatory Capital Rule: Risk-Based Capital Surcharges for Global Systemically Important Bank Holding Companies; Systemic Risk Report (FR Y-15), 88 Fed. Reg. 60385 (Sept. 1, 2023).
