SPST-0185 2015 Renewal - Resolution Plans Required for IDIs Over $50 Billion

SPST-0185 2015 Renewal - Resolution Plans Required for IDIs Over $50 Billion.docx

Resolution Plans Required for Insured Depository Institutions With $50 Billion or More in Total Assets

OMB: 3064-0185

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Supporting Statement

Resolution Plans Required for Insured Depository

Institutions With Over $50 Billion in Total Assets

OMB Control No. 3064-0185



A. Justification.


1. Circumstances that make the collection necessary:


The FDIC's roles as insurer and receiver require a distinct focus on potential loss severities, default risks, complexities in structure and operations, and other factors that impact risk to the Deposit Insurance Fund and the ability of the FDIC to conduct an orderly resolution. The FDI Act gives the FDIC broad authority to carry out its statutory responsibilities, and to obtain the information required by the Rule. The FDI Act gives the FDIC broad authority to carry out its statutory responsibilities, and to obtain the information required by the Rule. The authority to issue the Rule is provided by Section 9(a) Tenth of the FDI Act, 12 U.S.C. 1819(a) Tenth, which authorizes the FDIC to prescribe, by its Board of Directors, such rules and regulations as it may deem necessary to carry out the provisions of the FDI Act or of any other law that the FDIC is responsible for administering or enforcing.


Since the recent financial crisis began in late 2008, financial authorities throughout the world have recognized and agreed that advance planning for the resolution of large, complex financial institutions is critical to minimizing the disruption that a failure of such an institution may have as well as the costs of its resolution.


2. Use of the information:

This Rule requires an insured depository institution with $50 billion or more in total assets to submit periodically to the FDIC a contingent plan for the resolution of such institution in the event of its failure (Resolution Plan). The Rule established the requirements for submission and content of a Resolution Plan, as well as procedures for review by the FDIC. The Rule requires a covered insured depository institution (CIDI) to submit a Resolution Plan that should enable the FDIC, as receiver, to resolve the institution under Sections 11 and 13 of the Federal Deposit Insurance Act (FDI Act), 12 U.S.C. 1821 and 1823, in a manner that ensures that depositors receive access to their insured deposits within one business day of the institution's failure (two business days if the failure occurs on a day other than Friday), maximizes the net present value return from the sale or disposition of its assets and minimizes the amount of any loss to be realized by the institution's creditors. The Rule was intended to address the continuing exposure of the banking industry to the risks of insolvency of large and complex insured depository institutions, an exposure that can be mitigated with proper resolution planning.

In addition, this Rule requires that each CIDI submit a new Resolution Plan on or before the anniversary date of its initial plan. And the rule requires that a CIDI file a notice within 45 days after any event, occurrence, change in conditions or circumstances, or change which results in, or could reasonably be foreseen to have a material effect on its resolution plan, such that the resolution plan would be ineffective or require material amendment to be effective.


3. Consideration of the use of improved information technology:


Respondents may use any information technology that permits review by FDIC examiners.


4. Efforts to identify duplication:


The information required is unique. It is not duplicated elsewhere.


5. Methods used to minimize burden if the collection has an impact on a substantial number of small entities:


Not applicable.


6. Consequences to the Federal program if the collection were conducted less frequently:


Conducting the collection less frequently would present safety and soundness risks.


7. Special circumstances necessitating collection inconsistent with 5 CFR Part 1320:


None. The information collection is conducted in accordance with OMB guidelines in 5 CFR part 1320.


8. Efforts to consult with persons outside the agency:


A Federal Register notice seeking comment was published on February 6, 2015. (80 FR

6711). No comments were received.


9. Payment to respondents:


None.


10. Any assurance of confidentiality:


FDIC will ensure that information will be kept private to the extent allowed by law.


11. Justification for questions of a sensitive nature:


There are no questions of a sensitive nature.


12. Burden estimates:


A. Estimated Number of Respondents for Contingent Resolution Plan: 37.

Frequency of Response: Once.

Estimated Time per Response: 7,200 hours per respondent.

Estimated Total Initial Burden: 266,400 hours.


B. Estimated Number of Respondents for Annual Update of Resolution Plan: 37.

Frequency of Response: Annual.

Estimated Time per Response: 452 hours per respondent.

Estimated Total Initial Burden: 16,724 hours.


C. Estimated Number of Respondents for Notice of Material Change Affecting Resolution Plan: 37.

Frequency of Response: Zero to two times annually.

Estimated Time per Response: 226 hours per respondent.

Estimated Total Initial Burden: 8,362 hours.


13. Estimate of annualized costs to respondents:


None.


14. Estimate of annualized costs to the government:


None.


15. Changes in burden:


No change.


16. Information regarding collections whose results are planned to be published for statistical

use:


No publication for statistical use is contemplated.


17. Display of expiration date:


Not applicable.


18. Exceptions to certification statement:


Not applicable.



B. Collections of Information Employing Statistical Methods.


Not applicable.

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