ICBA sent a letter to the FDIC saying it supports the proposal to raise the applicability threshold to exempt institutions below $100 billion in assets from the rule’s resolution submission requirements.

ICBA said resolution planning requirements should be focused on those institutions whose size, complexity, and operational characteristics pose the greatest challenge for the FDIC to resolve and present the greatest potential for losses to the Deposit Insurance Fund, but the FDIC should not weaken substantive resolution planning requirements necessary to ensure that large banks are resolvable in practice.