Comptroller Issues Statement Explaining Vote Against Resolution Plan Feedback for American Express, Reasserts Need for Reforms to Resolution Planning

When regulators split on whether a resolution plan meets statutory standards, the public sees only the outcome, not the decision chain that produced it. The Comptroller's public dissent signals that the interagency process lacked a structured record of how each participant weighed the evidence, applied the criteria, and reached a conclusion. A decision governance framework would require each agency to document its rationale before issuing joint feedback, creating a contemporaneous record of the assessment logic and preventing post-hoc disagreement over what was actually decided. Resolution planning is itself a high-stakes decision process; the regulators evaluating those plans should be held to the same standard of rigor they demand from the institutions they supervise.