SIFMA And BPI Offer Recommendations On Resolution Planning Guidance

SIFMA and the Bank Policy Institute (collectively, the "associations") submitted comments to the Federal Reserve Board and the FDIC (collectively, the "agencies") regarding resolution planning guidance for eight large complex U.S. banking organizations.

In a joint comment letter, the associations expressed their general support for the agencies' intention to revise guidance, issued in 2016, for future resolution plan submissions in order to "streamline the firms' submissions and to provide additional clarity." The associations offered the following recommendations, among others:

• the agencies should acknowledge that an effective version of a single-point-of-entry resolution strategy is a credible means of resolving a global systemically important bank;