The FDIC's proposal contains little new information, but shines light on the outstanding key issues even if only by its silence.
The FDIC last week released its long awaited proposal on Single Point of Entry (“SPOE”) under Dodd-Frank’s Title II resolution framework. Although the proposal contains little new information, its value may be in its utility as a roadmap of outstanding issues, especially because a significant portion of it requests comment for public input.
Since its release, two FDIC board members have highlighted areas that need to be resolved, and key issues were discussed at a recent meeting of the FDIC’s Systemic Resolution Advisory Committee. While the FDIC deserves credit for making progress, SPOE as the way forward on resolving G-SIFIs remains far from the goal line.
This Financial Services Regulatory Brief updates our previous brief on SPOE with our latest view of the outstanding issues.