To the Editor:

The Dec. 7 article "Creditors Fear New Resolution Process" incorrectly characterizes the debate over a resolution authority framework as a choice between only two options — relying on the bank insolvency statute or using only the bankruptcy code during a resolution — and portrays the Securities Industry and Financial Markets Association as opposing reform.

In fact, SIFMA has been very vocal in calling for legislation to establish resolution authority that ensures no institution is too big to fail. We have been advocating a melding of the best parts of the two statutes into a process that will protect against systemic risk while providing a clear, unambiguous wind-down process for all parties — especially secured creditors.

Ensuring a viable resolution process is one of the most important pieces of regulatory reform and is an issue we've been working very hard on, providing thoughtful, constructive feedback to members of Congress. This is a very complex issue, and we must get the legislation right because a resolution process established incorrectly would end up increasing systemic risk, not decreasing it. American Banker's readers deserve more accurate reporting of this critical debate.

T. Timothy Ryan Jr.
President and CEO
SIFMA, Washington

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