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Understanding U.S. Regulator’s Proposed Extended Comment Period

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Earlier this year, the Office of the Comptroller of the Currency (OCC), the Board of Governors of the Federal Reserve System (Fed), and the Federal Deposit Insurance Corporation (FDIC) unveiled a proposed rule that would reshape the landscape for certain financial institutions.

In this article, we delve into the latest developments around the extended comment period, providing stakeholders an increased opportunity to share their insights.

A Brief Overview

Initially slated for comments by November 30, 2023, the proposed rule mandates specific financial institutions to issue and maintain a minimum amount of outstanding long-term debt (LTD), including:

  • Large depository institution-holding companies
  • U.S. intermediate holding companies of foreign banking organizations
  • Select insured depository institutions

The intent behind this regulatory move is to enhance the stability and resilience of these institutions by fostering responsible financial practices.
Learn More: U.S. Regulators to Bank Boards: “Debt is Good”

Crucial Update: Extension of the Comment Period

Since Perficient’s Risk and Regulatory Compliance Center of Excellence (CoE) analyzed this decision in September, a significant development has occurred. On November 22, 2023, the FDIC released an update titled “Agencies Extend Comment Period on Proposed Rule to Require Large Banks to Maintain Long-Term Debt.”

This extension stretches the original comment deadline to January 16, 2024, providing stakeholders with an additional window to thoroughly analyze and provide thoughtful commentary.

How to Engage in the Commenting Process

Stakeholders are strongly encouraged to actively participate in the commenting process, leveraging the extended timeframe until January 16, 2024. To submit your comments to the OCC, we suggest exploring the following methods:

  • Visit the Federal Rulemaking Portal: Visit, enter “Docket ID OCC–2023–0011” in the Search Box, and click “Search.” Submit public comments via the “Comment” box below the displayed document information.
  • Email: Send your comments to
  • Mail: Forward your comments to Chief Counsel’s Office, Attention: Comment Processing, Office of the Comptroller of the Currency, 400 7th Street SW, Suite 3E–218, Washington, DC 20219.
  • Hand Delivery/Courier: Personally deliver your comments to 400 7th Street SW, Suite 3E–218, Washington, DC 20219. Ensure “OCC” is the agency name, and “Docket ID OCC–2023–0011” is in your comment.

It’s important to note that the OCC will include all received comments in the docket and publish them on the website without alterations, maintaining confidentiality.

Navigating the New Landscape

For more understanding of the proposed rule, the federal register notice from the Department of The Treasury (OCC), Federal Reserve Board, and Federal Deposit Insurance Corporation is available here: Federal Register Notice.

Connect with Our Experts

For those seeking more guidance and insight into specific risk and regulatory challenges, our experts from the Risk and Regulatory Compliance CoE are here to help.

Our industry knowledge in financial services, coupled with digital leadership across platforms and business needs, empowers large organizations to navigate complex challenges and foster growth.

Contact us today or explore our Financial Services solutions options to see how Perficient can further propel your business.

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Ashley Simmons

Ashley has over 20 years of experience in financial services, managing and collaborating on large-scale economic initiatives. Her expertise involves overseeing and driving solutions to support risk and regulatory compliance scopes. She has hands-on experience conducting risk data analysis, technology-based issue management analysis, third-party risk management lifecycle processes, transformation process improvement, Senior Technical Writing, and auditing Federal Reserve/CFPB/OCC-related initiatives.  

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