Thoughts on Single Point of Entry

Abstract

This comment letter was recently submitted to the FDIC in response to their Single Point of Entry (SPOE) Strategy for implementing Dodd Frank’s Orderly Liquidation Authority (Federal Register/Vol. 78, No. 243).

In the comment letter, I describe SPOE as a promising first start, but urge the agency to develop an more realistic description of the process that includes financial distress at the operating subsidiary level.

Holding companies are unlikely to be the direct source of financial distress that would warrant the use of OLA, yet the SPOE proposal as explicated is almost exclusively focused on holding companies. Certainly resolving holding companies is much easier than resolving operating companies, but if the SPOE is to provide a realistic roadmap for future use of OLA, it must engage in a full discussion of a more realistic, and specific scenario.

Keywords: FDIC, SPOE, OLA, Dodd-Frank, too big to fail, TBTF

JEL Classification: G21, G24, G28, G32, G38, K22, K23, K29