OCC Comptroller Abstains from FDIC GSIB Resolution Plan Vote
Comptroller Gould abstained from FDIC vote on feedback for July 2025 Dodd-Frank 165(d) resolution plans, citing fundamental issues with current resolution planning processes.
Public abstention signals interagency disagreement on US GSIB resolution planning. The OCC is signaling intent to reassess the substance and burden of Title I resolution plans, raising the prospect of revised expectations or methodology changes affecting GSIB resolvability assessments.
Resolution planning shapes capital, liquidity, legal entity rationalization, and operational continuity requirements for GSIBs.
Action Required
Review GSIB resolution planning assumptions and prepare for potential regulatory divergence between OCC and FDIC on living will expectations.
Interagency split on GSIB resolution standards is a strategic signal for systemic banks.
Monitor potential divergence between OCC and FDIC on 165(d) resolution plan expectations; reassess assumptions in living will program governance.
“Comptroller Gould issued statement on his abstention from the FDIC vote on feedback concerning July 2025 Dodd-Frank Section 165(d) resolution plans of US GSIBs, citing fundamental issues with current resolution planning processes.”