WASHINGTON—Comptroller of the Currency Jonathan V. Gould issued a statement today on his Federal Deposit Insurance Corporation (FDIC) votes concerning resolution planning, assessments, and the disclosure of confidential supervisory information.
Excerpts from Comptroller Gould’s statement are below. His full statement can be found here.
On resolution planning:
I am voting for the proposal to revise resolution-related submissions for insured depository institutions over a certain asset size because I believe that it is a meaningful step in the right direction. It is a recognition that the FDIC should not attempt to outsource its resolution responsibilities to banks, narrows the scope of covered banks subject to the information collection requirements, and reduces certain of those same requirements.
However, the proposal does not fully address my concerns. And I strongly encourage stakeholders to provide comment on what is right with the proposal and what more should be done, including whether specific information requirements – such as those targeting digital asset activities – are warranted and whether they might be used by a future Administration to chilling effect or otherwise be unnecessary. As I contemplate a final rule in this area, I will also seek changes in FDIC structure and staffing that reduce bureaucratic incentives to perpetuate or expand this exercise in the future. Board focus and FDIC resources are better spent rebuilding resolution execution capabilities than perpetuating the compliance exercise known as resolution planning.
On assessments:
I support the proposal to revise aspects of the deposit insurance assessments framework because I believe that the changes to the thresholds and resolution readiness adjustments are concepts worth investigating through notice and comment.
The proposed optional downward resolution readiness adjustment is creative, and I expect the comment process to be helpful in assessing how well this new idea would work in practice. At a minimum, banks should be able to understand clearly the work required and the FDIC’s standards for applying the downward adjustments, and the FDIC should adjust the requirements so that banks find it worthwhile to develop and maintain these capabilities.
On the disclosure of confidential supervisory information:
I am voting for the proposal to revise the FDIC’s regulation governing the disclosure of confidential information by allowing banks to disclose this information without agency approval when necessary or appropriate for business purposes because it should allow banks to more effectively manage their operations.
However, I believe that the final rule should go further, and I encourage commenters to address other ways in which the FDIC could reasonably expand access to confidential supervisory information, including by addressing the many specific questions in the preamble. The regulatory framework should facilitate the disclosure of confidential information not only in furtherance of an institution’s business purposes but also in the service of accountability and transparency. These objectives help to ensure that the public understands and has confidence in our supervision and are essential to the proper functioning of our financial system and good government.
