Acting Comptroller Issues Statement on FDIC and Federal Reserve Board ANPR on Resolution-Related Resource Requirements for Large Banking Organizations

News Release 2022-129 | October 18, 2022

WASHINGTON—Acting Comptroller of the Currency Michael J. Hsu today issued the following statement at the Federal Deposit Insurance Corporation (FDIC) board meeting:

I support the FDIC’s joint issuance with the Federal Reserve of this Advance Notice of Proposed Rulemaking (ANPR) on resolution-related resource requirements for large banking organizations.

The time is right for this ANPR. As I noted in remarks I gave at the Wharton School of the University of Pennsylvania in April of this year, the growth of large U.S. banking organizations warrants our attention. The number, size, and complexity of large banks – especially non-global systemically important banks (GSIBs) – have increased materially over the years. Reevaluating the resolvability risks and requirements for these firms will help to mitigate the risk of a new class of too-big-to-fail firms from emerging.

At the same time, it is critical that our actions as regulators promote competition. The same firms that led the banking system in terms of size over a decade ago continue to lead the banking system today, raising questions about competitiveness at the largest banks.

This joint ANPR represents a concrete step towards addressing the twin imperatives of financial stability and competition. Exploring the development of a rule that can ensure the resolvability of large, domestically-systemic banks will promote financial stability by guarding against the rise of non-GSIBs that may become too-big-to-fail, while enabling true competition amongst the largest banks.

Regulators should not be forced to choose between financial stability and competition. We need to find a way to achieve both. This ANPR puts us on that path.

The ANPR also complements long-standing work by the Basel Committee on Bank Supervision with regard to domestic systemically important banks, or D-SIBs.

For these reasons, I strongly support the ANPR and look forward to public feedback on it.

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