Via Electronic Mail
Federal Deposit Insurance Corporation
550 17th Street NW
Washington, DC 20429
Attention: Jennifer Jones, Counsel
OMB No. 3064–0185

Office of Information and Regulatory Affairs
Office of Management and Budget
New Executive Office Building
Washington, DC 20503
OMB No. 3064–0185

Re: Agency Information Collection Activities: Proposed Collection Renewal; Comment Request (OMB No. 3064–0185)

Ladies and Gentlemen:
The Bank Policy Institute (BPI) and the Securities Industry and Financial Markets Association (SIFMA and, together, the Associations)1 appreciate the opportunity to respond to the Federal Deposit Insurance Corporation’s (the FDIC) notice and request for comment on the proposal to renew the IDI Rule’s2 information collection requirement (the Renewal Proposal).

The Associations believe that:

• the FDIC staff should provide forward-looking guidance on IDI Plan requirements that is applicable to all filers on a public rather than confidential basis as is the practice for 165(d) Plans, and
• the informational requirements for IDI Plans and 165(d) Plans should be harmonized, allowing filers to focus their resolution planning efforts on a single resolution plan filing containing information and
  analysis that is most applicable to their business model and risk profile while also lowering the burden of review by agency staff.

Implementing these changes to the IDI Plan submission and feedback process will improve the usefulness of the information collected pursuant to the IDI Rule and minimize the associated burden on filers.

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