OCC Comptroller Votes Against AmEx Resolution Plan Letter, Urges Reform
Comptroller Jonathan Gould opposed a joint FDIC-Fed letter to American Express and called for overhaul of Dodd-Frank resolution planning rules.
Comptroller of the Currency Jonathan V. Gould publicly opposed a joint resolution plan feedback letter issued by the Federal Deposit Insurance Corporation and the Federal Reserve Board to American Express, the OCC announced. Gould released a formal statement explaining the reasoning behind his dissenting vote, a step that signals notable tension among federal banking regulators on how institutions should prepare for potential failure scenarios.
The dispute centers on Dodd-Frank Act Section 165(d), the provision that requires large financial firms to submit so-called living wills — detailed blueprints outlining how they could be wound down in an orderly fashion without triggering broader financial instability or requiring a taxpayer-funded bailout. Gould's objection was not simply a procedural disagreement; he used the occasion to reassert a broader argument that the existing resolution planning framework itself is in need of structural reform.
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By breaking with the FDIC and the Federal Reserve on the joint letter to American Express, Gould drew attention to what he characterized as deficiencies in the current regulatory approach. The move underscores ongoing debate within the federal financial oversight community about whether Dodd-Frank's resolution planning regime is functioning as Congress intended or has grown unwieldy and in need of modernization.
The OCC's stance could carry practical implications for how resolution planning reviews are conducted and coordinated across agencies going forward. Regulators and industry observers will likely watch for whether Gould's public dissent prompts legislative or interagency discussions about updating Section 165(d) standards. Continue reading at OCC News.
