Banking Agencies Request Feedback on a Proposal to Strengthen Large Bank Resolution Standards

The Federal Reserve Board and the FDIC (the "Banking Agencies") issued an advance noticed of proposed rulemaking ("ANPR") to solicit feedback on "whether an extra layer of loss-absorbing capacity could improve optionality in resolving a large banking organization or its insured depository institution, and the costs and benefits of such a requirement."

In the ANPR, the Banking Agencies said that the proposed enhancements to certain resolution planning requirements would distinguish between the standards applied to global systemically important banks ("GSIBs") and other large banks. Further, the Banking Agencies requested input on how, if at all, elements of the GSIB standards could be tweaked and applied to large banks in general. The Banking Agencies are seeking information on:

• implementing an appropriately adapted long-term debt requirement, which would create an additional resolution option through its support of a single-point-of-entry strategy that focused on holding-company level resolution;

• appropriate form and content changes to large bank disclosure requirements; and

• establishing, if necessary, any separability requirements in the contexts of recovery or resolution.

Comments are due within 60 days after publication of the ANPR in the Federal Register.