FDIC board approves notice to streamline resolution-submission rules, raising asset threshold to $100 billion

The Federal Deposit Insurance Corporation board on the open agenda voted to publish a notice of proposed rulemaking that would substantially narrow the institutions required to file detailed "resolution submissions" and refocus required materials toward operational information most directly needed for executing a resolution.

FDIC staff told the board the proposal would increase the covered-asset threshold from $50 billion to $100 billion, adopt automatic indexing for future threshold adjustments, and replace voluminous narrative strategy submissions with more succinct, targeted information about corporate structure, key personnel, information systems mapping, material loan portfolios, deposit activities and qualified financial contracts. "We appreciate the opportunity to present to you the proposal for amendments," a staff presenter said in opening remarks.

The move would put 16 of the 48 currently covered institutions outside the rule, staff said, and place all remaining covered firms on a three-year submission cycle (with certain U.S. government subsidiaries on a two-year cycle). The proposal would eliminate interim supplements and the current requirement for a public section of submissions, and would rely on existing extraordinary-event reporting to surface material changes between full submissions. Staff also said credibility assessments and some historical content requirements would be eliminated.

Chairman Hill framed the changes as an effort to ensure the FDIC receives the information most pertinent to resolution execution rather than long narrative plans. He described the proposal as intended to "maximize the likelihood of an optimal resolution outcome" by improving the agency's preparedness.

Director Gould said he supports the proposal as a meaningful step toward refocusing FDIC resources on resolution execution rather than outsourcing those responsibilities to banks, but urged commenters to identify remaining gaps. He cautioned that certain information requirements—particularly those addressing digital-asset activities—should be examined to avoid unintended consequences and asked the public to comment on how the proposal might be improved.

The board adopted a resolution to publish the notice for public comment. The motion was moved and seconded and the chair called the roll; the motion was adopted on the record (the transcript records affirmative 'I' votes; a full roll-call tally is not specified). Initial submissions under a final rule would be due no earlier than 270 days after the final rule's effective date, staff said, and the board requested transitional exemptions for institutions that become subject to current rules prior to the final rule's effective date.

The notice will be published with an opportunity for public comment; staff indicated they will respond to comments received during the rulemaking record.