Americans for Financial Reform Education Fund raised concerns over weakening resolution planning requirements intended to prepare large bank holding companies for an orderly resolution in conventional bankruptcy without risk to financial stability and without any reliance on extraordinary public support of the failed bank or its counterparties.
Americans for Financial Reform Education Fund sent a letter to banking regulators opposing a proposal that would make the resolution planning process substantially less stringent than it currently is, and raising concerns over the safety and soundness of individual banks and the effect on U.S. financial stability.
Several safeguards are critical to ensure that bank loan programs—particularly those designed for financially distressed consumers—promote financial inclusion rather than exacerbate financial exclusion and distress.
The need for strong public interest nominees is even greater today. This Administration has been
filling key regulatory positions with people pursuing Wall Street’s agenda at the public’s expense,
and the revolving door is spinning faster than ever. There is an enormous amount at stake at both
the SEC and FDIC as the financial industry and their friends in the Trump administration work to
undo the progress made in Dodd-Frank and to undermine key investor protection standards.
“ILC charters exploit a loophole in federal banking laws to gain access to the federal deposit-insurance safety net while avoiding critical federal supervision and regulation. ILCs therefore pose unique risks to the financial system… If these applications are granted, [it] will send a clear signal to the marketplace that the FDIC intends once again to approve ILC deposit insurance applications, potentially unleashing a dangerous avalanche of new applications.”
“…The essence of SoFi’s application is a request to seek the benefits of federal deposit insurance without subjecting SoFi itself or its private equity owners to the well-founded requirements for bank holding companies. The FDIC should not approve the application to facilitate this regulatory arbitrage. …If its application is granted, SoFi will be the first new ILC to secure deposit insurance in over a decade. That will send a clear signal to the marketplace that the FDIC intends once again to approve ILC deposit insurance applications. FDIC should not grant SoFi’s application and allow the ILC loophole to be revived.”