Joint Comment Letter on the Proposed 165(d) Rule Amendments

Board of Governors of the Federal Reserve System
20th Street and Constitution Avenue, NW
Washington, D.C. 20551
Attention: Ann E. Misback, Esq., Secretary
Docket No. R-1660

Federal Deposit Insurance Corporation
550 17th Street NW
Washington D.C. 20429
Attention: Robert E. Feldman, Executive Secretary
RIN 3064-AE93

Ladies and Gentlemen:

The Bank Policy Institute (BPI), the Securities Industry and Financial Markets Association (SIFMA) and the American Bankers Association (ABA and, together, the Associations) appreciate the opportunity to comment on the Board of Governors of the Federal Reserve System’s (the Federal Reserve) and the Federal Deposit Insurance Corporation’s (the FDIC and, together, the Agencies) proposal (the 165(d) Proposal) to amend and restate the jointly issued regulation (the 165(d) Rule) implementing the resolution planning requirements of section 165(d) (Section 165(d)) of the Dodd-Frank Wall Street Reform and Consumer Protection Act (the Dodd-Frank Act). This letter begins with our support for the 165(d) Proposal, which we believe preserves the key elements of an effective resolution planning process and does not undermine the work that has and will continue to be done to eliminate obstacles to orderly resolution. The filers appreciate the imperative of having a credible resolution plan, and the 165(d) Proposal would continue to require them to maintain and enhance their resolvability over time. The core elements of the proposed revisions to the 165(d) Rule are important and welcomed, and this letter provides limited technical comments on areas for suggested refinement and responds to certain issues raised for comment in the NPR.

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