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Final Title I Resolution Planning Guidance for Triennial Full Filers

I plan to vote in favor of the final Title I resolution plan guidance for domestic and foreign triennial full filers.  I agree with the decision not to provide specific guidance on derivatives and trading activities given the relatively small size of these activities for triennial filers, and I appreciate the agencies’ clarification that foreign triennial filers are not expected to include information about their global resolution plans when such firms do not have access to those plans.1  Additionally, I support the extension of the next resolution plan submissions for these firms until October 1, 2025, which is consistent with the agencies’ commitment under the rule to provide at least one year following the finalization of any guidance,2 and for which I have strongly advocated.3

Although I will vote in favor of the final guidance, I do have a few reservations.  I think we may want to revisit this guidance in the future, depending on whether and how the proposed long-term debt rule4 is finalized.  Relatedly, at some point it may be worth exploring an “SPOE-lite” approach for non-GSIBs with an SPOE resolution strategy.  I also continue to have some skepticism of requiring firms with an MPOE resolution strategy to explain how an IDI resolution would comply with the least-cost test, given that we have a separate resolution planning rule governing IDIs,5 and given the substantial uncertainty around trying to estimate the cost of resolution options at the point of failure.

Nonetheless, I plan to vote in favor of the guidance and would like to thank the staff for their continued work on this issue.

Last Updated: August 12, 2024