View or download a PDF of the letters here:

• Fed, FDIC, OCC Long-Term Debt Requirements
• Fed, FDIC Guidance for Resolution Plan Submissions
• FDIC, Resolution Plans for Insured Depository Institutions

AFREF submitted comments supporting proposals from the Federal Reserve, the Federal Deposit Insurance Corporation, and the Office of the Comptroller of the Currency, which would strengthen and expand applicability of resolution plan rules and guidance and require more large banks (in the Fed’s large bank tailoring framework) to hold a certain amount of long term debt in their liability structure. While we support these proposals, they must not distract or be seen as substitutes for stronger capital requirements (particularly for the largest banks) as embodied in the large bank capital and GSIB surcharge proposals.