Comptroller Issues Statement Explaining Vote Against Resolution Plan Feedback for American Express, Reasserts Need for Reforms to Resolution Planning — 2026-09-29

WASHINGTON—Comptroller of the Currency Jonathan V. Gould today issued a statement on his vote against a joint resolution plan letter from the Federal Deposit Insurance Corporation and the Federal Reserve Board to American Express and reaffirmed the need for reforms to Dodd-Frank Act Section 165(d) resolution plans. Excerpts from Comptroller Gould’s remarks are below. His full statement can be found here. Opacity and uncertainty remain hallmarks of the resolution planning process, and we should not allow them to continue. The agencies are telling a non-systemically important bank to address significant concerns with its resolution strategy without detailing these concerns or explaining the potential consequences if they are not addressed; (2) the agencies retain full discretion to take more severe action if these concerns are not addressed in the next plan; and (3) the options that would likely best protect the company from these consequences are costly to