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;
  • the resolution planning submission process should be streamlined by having a two-year submission and review cycle;
  • all applicable resolution planning requirements should be consolidated and made public, and all past guidance that is not consolidated and made public should be deemed suspended;
  • the agencies should engage more proactively with non-U.S. regulators to improve the efficiency of resolution planning requirements;
  • the payment, clearing and settlement ("PCS") analysis should be confined to matters relevant to the successful execution of a filer's resolution strategy;
  • the final guidance should clarify the definition of a provider of PCS services;
  • the funding and liquidity analysis required by PCS playbooks should align with the liquidity requirements in other parts of the final guidance; and
  • the agencies should limit the "firm-wide" derivatives capabilities and requirements to a dealer firm's material entities, rather than across both material entities and non-material entities.

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