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Statement by Martin J. Gruenberg,
Member, FDIC Board of Directors, Issuance
of a Notice of Advance Notice of Proposed
Rulemaking: Resolution Plans Required for
Insured Depository Institutions with $50
Billion or More in Total Assets
The FDIC Board today is considering an Advance Notice of Proposed Rulemaking
(ANPR) as part of a review of its rule requiring insured depository institutions (IDIs) with
$50 billion or more in total assets to submit plans for their orderly resolution under the
Federal Deposit Insurance Act. In addition, the Board resolution would delay indefinitely
the next submission of these plans until the review of the rule and any resulting Board
action is complete.
I believe there is reason for the FDIC to review the implementation of its insured
depository institution resolution plan rule. In my view, however, the proposed ANPR is
headed in the wrong direction. While it acknowledges the distinct challenges associated
with a large insured depository institution resolution under the Federal Deposit
Insurance Act, there is a disconnect in that the proposals are mainly focused on
reducing or eliminating resolution plan requirements, rather than making them a more
effective tool for managing the orderly failure of a large IDI. Moreover, in my view, an
indefinite delay of the submission of the next plans is unwarranted.
Taken together with the Notice of Proposed Rulemaking on resolution plan
requirements for the eight U.S. Global Systemically Important Banks (GSIBs) and other
large U.S. and foreign banking organizations under the Dodd-Frank Act, which the FDIC
Board just adopted, I am concerned that we are headed down a path of weakening the
entire resolution plan framework developed since the financial crisis.
For these reasons, I intend to vote against the proposed ANPR.
Statement by Martin J. Gruenberg,
Member, FDIC Board of Directors, Issuance
of a Notice of Advance Notice of Proposed
Rulemaking: Resolution Plans Required for
Insured Depository Institutions with $50
Billion or More in Total Assets
The FDIC Board today is considering an Advance Notice of Proposed Rulemaking
(ANPR) as part of a review of its rule requiring insured depository institutions (IDIs) with
$50 billion or more in total assets to submit plans for their orderly resolution under the
Federal Deposit Insurance Act. In addition, the Board resolution would delay indefinitely
the next submission of these plans until the review of the rule and any resulting Board
action is complete.
I believe there is reason for the FDIC to review the implementation of its insured
depository institution resolution plan rule. In my view, however, the proposed ANPR is
headed in the wrong direction. While it acknowledges the distinct challenges associated
with a large insured depository institution resolution under the Federal Deposit
Insurance Act, there is a disconnect in that the proposals are mainly focused on
reducing or eliminating resolution plan requirements, rather than making them a more
effective tool for managing the orderly failure of a large IDI. Moreover, in my view, an
indefinite delay of the submission of the next plans is unwarranted.
Taken together with the Notice of Proposed Rulemaking on resolution plan
requirements for the eight U.S. Global Systemically Important Banks (GSIBs) and other
large U.S. and foreign banking organizations under the Dodd-Frank Act, which the FDIC
Board just adopted, I am concerned that we are headed down a path of weakening the
entire resolution plan framework developed since the financial crisis.
For these reasons, I intend to vote against the proposed ANPR.