The Office of the Comptroller of the Currency published a statement from Comptroller Jonathan V. Gould explaining why he abstained from the Federal Deposit Insurance Corporation vote on draft feedback letters for the July 2025 Dodd-Frank Act Section 165(d) resolution plans of U.S. global systemically important banks. He said the proposed letters are relatively benign compared with prior years and identify no new shortcomings or deficiencies, but he would not endorse them because they continue a resolution planning process that he considers fundamentally flawed and extralegal. Gould argued that the Federal Deposit Insurance Corporation and Federal Reserve have used feedback letters and guidance to impose binding and burdensome requirements without prior notice or opportunity for comment, citing capital and liquidity concepts such as RCAP, RCEN, RLAP and RLEN and more recent expectations around assurance frameworks and contingency strategies. He said progress is being made on reforming the Federal Deposit Insurance Corporation's CIDI resolution plan requirements, but not on Section 165(d) planning for GSIBs, which he said has evolved from plan review into broader capabilities and assurance requirements with limited incremental value. Looking ahead, he said the latest letters leave the scope of review and areas of focus for next year's plans undefined, although they appear to point to further capabilities testing. He called for longer intervals between submissions and a broader review of the resolution planning guidance and prior feedback that, in his view, has created significant burden without commensurate value.
Office of the Comptroller of the Currency2026-05-22
Office of the Comptroller of the Currency Comptroller abstains from Federal Deposit Insurance Corporation vote on GSIB resolution plan feedback citing flawed Section 165(d) process
The Office of the Comptroller of the Currency released a statement from Comptroller Jonathan V. Gould explaining his abstention from the FDIC vote on draft feedback letters for the July 2025 Dodd-Frank Act Section 165(d) resolution plans of U.S. global systemically important banks, citing a fundamentally flawed, extralegal process. Gould said the FDIC and Federal Reserve have used feedback letters and guidance to impose binding requirements without notice and comment, and that Section 165(d) planning has shifted from plan review to broader capabilities expectations with limited value. He urged longer intervals between submissions and a broader review of resolution planning guidance and prior feedback, warning that the latest letters leave future review scope undefined while signaling further capabilities testing.