Statement by Jonathan McKernan, Director, FDIC Board of Directors, on the Proposed Guidance for Resolution Plan Submissions of Triennial Full Filers

I support today’s proposed guidance for Section 165(d) resolution plan submissions of triennial full filers. I do find it challenging to assess aspects of this proposal, in particular the guidance relating to the “multiple-point-of-entry” strategy, in the context of the unanswered questions raised by today’s proposed long-term debt and resolution planning requirements. Ideally, we might have finalized those two proposals before proposing this guidance. However, the events of March and April establish that there is some urgency to our remaining work to develop an effective framework for resolving failed banks, and so I do still support moving forward with proposing this guidance at this time. That said, my support for the final guidance will be conditioned on a reasonable and transparent timeline and approach to expecting the incorporation of the final guidance into future rounds of resolution plan submissions.