BPI Submits Comment Letter to Fed, FDIC on Resolution Planning Requirements

On June 21, BPI (joined by SIFMA and the ABA) submitted a comment letter to the Federal Reserve and FDIC on their proposed revisions to regulations governing resolution planning requirements for banks as mandated by section 165(d) of the Dodd-Frank Act. The letter identifies several areas for refinement and clarification within the proposal’s risk-based framework for filing frequency and content requirements, recommending revisions to the proposed timing of requests, notifications and other deadlines, as well as to elements of the proposal’s requirements for the plans’ informational content.