US OCC chief calls bank living wills “seriously flawed”, abstains from voting

US Comptroller of the Currency Jonathan V. Gould has abstained from a Federal Deposit Insurance Corporation (FDIC) ballot connected unit feedback relating to the July 2025 Dodd-Frank Act Section 165(d) solution plans.

The FDIC and the Federal Reserve Board published feedback letters covering respective solution plans filed successful July 2025.

Resolution plans, commonly described arsenic surviving wills, are required to acceptable retired however a banking organisation would beryllium resolved successful an orderly mode if it faced superior fiscal accent oregon failure.

The agencies carried retired a associated appraisal of 2025 submissions from the 8 largest and astir analyzable home banking organisations, on with 56 overseas banking organisations.

Both the Federal Reserve and FDIC said they recovered nary “shortcomings oregon deficiencies” successful the latest plans, noting erstwhile issues person been “satisfactorily addressed” successful these submissions.

On his part, Gould released a connection connected his abstention from FDIC ballot connected solution program feedback.

“I americium abstaining from voting connected the FDIC staff’s connection regarding the solution plans of the U.S. planetary systemically important banks (GSIBs) due to the fact that I judge that determination are cardinal issues with the existent solution readying processes that proceed to beryllium unaddressed,” helium said.

According to him, the feedback letters remainder on, and continue, a “seriously flawed and, successful my opinion, extralegal process”.

Gould pointed backmost to remarks helium delivered 5 months earlier, wherever helium acceptable retired ineligible and conceptual objections to solution readying astatine some the slope and holding-company tiers.

He said enactment is nether mode to alteration the FDIC’s requirements for insured depository instauration (CIDI) solution plans, but that Section 165(d) plans person not yet been the focus, and helium said that discourse informed his abstention.

Gould said the latest worldly did not acceptable retired caller “shortcomings” oregon deficiencies.

He said the existent letters notation to firms gathering further items that had been introduced done earlier feedback, including “assurance” and “contingency strategies.”

He noted that successful 2024 the Federal Reserve and the FDIC told US GSIBs, via feedback letters, that they expect an “assurance framework” for solution capabilities, made up of astatine slightest 5 elements listed successful those letters.

According to the chief, the process has shifted from planning, to readying positive capabilities, to readying positive capabilities positive assurance of capabilities.

He added that determination is nary “assurance” that requirements added done feedback letters volition halt increasing.

On “contingency strategies,” Gould said the projected letters picture approaches for keeping captious operations moving “through a scope of alternate solution scenarios erstwhile fiscal resources are importantly little than the execution needs aft the Covered Company files for bankruptcy.”