Having received no challenge to its increase, by hundreds of thousands of hours, in the burden estimate for its resolution plan requirements for banks with $50 billion or more in assets, the federal bank deposit insurer is issuing its proposed renewal for a final public comment period that ends Nov. 28.
The Federal Deposit Insurance Corp. (FDIC) issued a notice for comment in July on the proposed renewal. In that notice, it said it was nearly doubling its annual regulatory burden estimate for the requirements, raising it by 281,305 hours to an aggregate 572,791 hours spent by the estimated 42 institutions required to submit the plans. The change followed a reassessment of the burden hours of responding to the existing requirements and other factors, including feedback received over the past year.
In response to the July notice, one commenter did suggest policy changes to the underlying rule, the FDIC said, but there were no comments addressing the FDIC’s revised burden estimate. The agency did note that the underlying rule, Section 360.10 of the FDIC’s regulations, is currently under review.
The plans are required under rules of the Federal Deposit Insurance Corp. (FDIC) that were made final in 2012. While they complement the resolution plan (aka “living will”) requirements for bank holding companies under the Dodd-Frank Wall Street Reform and Consumer Protection Act (Dodd-Frank), these plans are not a Dodd-Frank obligation. Instead, they are implemented under the FDIC’s liquidation and receivership authority under the Federal Deposit Insurance Act.