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

Re: Proposed 165(d) Rule Amendments

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)1 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).2 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 filers3 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.
The Associations support the Agencies’ continued efforts to calibrate and better focus the resolution planning process.

The Associations approve of the Agencies’ decision to revisit the 165(d) Rule. The annual iterative process put in place by the Agencies eight years ago when the 165(d) Rule was first promulgated was a wise path forward when resolution planning was new and unknown.4 The Associations appreciate the Agencies’ engagement with the filers over the years and their commitment to developing sophisticated approaches to resolution planning. The Agencies and the filers have, as a result, learned an immense amount about the essential components of an effective resolution planning process, and tremendous progress has been made towards eliminating obstacles to an orderly resolution and ensuring that filers can be resolved in a manner that does not pose risks to U.S. financial stability.

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