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WASHINGTON—Acting Comptroller of the Currency Michael J. Hsu, in his capacity as a Federal Deposit Insurance Corporation (FDIC) board member, today released the following statement on the FDIC’s review of the eight largest and most complex domestic banking organizations’ 2021 resolution plans.

The collaborative review of the plans by the FDIC and Federal Reserve Board identified areas in which each of the firms should continue to improve its capabilities to facilitate a rapid and orderly resolution. The agencies’ shortcoming determination with regards to Citigroup is consistent with the OCC’s supervisory cease and desist order issued against Citibank, N.A., in October 2020 to require the bank to take broad and comprehensive corrective actions to improve risk management, data governance, and internal controls.

Resolvability is about capabilities, not just passing a paper test. The agencies’ determination regarding Citigroup reflects and reinforces this.

The next Title I review will constitute the first full plan review under the elongated review cycle, which was adopted in 2019. A lot has changed in the intervening period. I will be particularly focused on assessments of firms’ legal entity rationalization and separability capabilities.

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