Justification Memorandum

Federal Deposit Insurance Corporation

550 17th Street NW, Washington, D.C. 20429-9990

550 17th Street NW, Washington, D.C. 20429-9990

March 2, 2021

 

Memorandum to:        William E. Bestani

                                    Policy Analyst 

                                    Office of Information and Regulatory Affairs

                                    Office of Management and Budget

 

From:                Manny Cabeza

Regulatory Counsel

                                    Federal Deposit Insurance Corporation

Legal Division

 

RE: Meetings Regarding Required Resolution Plans for Insured Depository Institutions with $100 Billion or More in Total Assets.

Under the generic clearance entitled, “Information Collection for Qualitative Research” (3064-0198), the FDIC hereby submits for OMB review the generic survey “Meetings Regarding Required Resolution Plans for Insured Depository Institutions with $100 Billion or More in Total Assets.”

In January 2021, the FDIC issued a statement entitled “FDIC Announces Lifting IDI Plan Moratorium” (the “Statement”). The Statement notes that the FDIC will provide further details surrounding its modified approach for implementing 12 C.F.R. § 360.10 (the “Rule”) for insured depository institutions with $100 Billion or more in total assets. There are approximately 31 institutions affected by this implementation of the Rule (the “Subject IDIs”).

The FDIC proposes to hold approximately six meetings, each expected to be attended by four to seven Subject IDIs to discuss and solicit feedback on this planned modified approach. Each Subject IDI will be invited to attend one of the meetings, and each meeting is estimated to last approximately 60 minutes.

Estimated Burden

Metric	Estimate
Insured depository institutions with $100 billion or more in total assets (the “Subject IDIs”) 1 meeting per Subject IDI (Subject IDIs will be divided into 6 groups) 60 minute meetings	31 Total institutions 31 Expected Institutions 31 Hours = 31 x 60 minute meetings
Total Estimated Burden	31 hours

Total estimated annual burden for this collection of information is approximately 31 hours.

If you have any questions, please let me know. Thank you for your consideration.

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