September 29, 2026

Agencies publish resolution plan feedback letters for 15 banking organizations

WASHINGTON — In a joint regulatory update released Monday afternoon, federal banking authorities announced that they have formally published feedback letters regarding the resolution plans submitted by 15 major banking organizations in October of last year. According to the announcement, which was issued jointly by the Federal Deposit Insurance Corporation (FDIC) and the Federal Reserve Board at 4:00 p.m. EDT, the regulatory agencies did not identify any shortcomings or deficiencies in the reviewed resolution plan submissions, marking a smooth evaluation cycle for the participating institutions.

Resolution plans, which are commonly referred to in the financial industry as "living wills," serve as critical regulatory tools designed to protect the broader economy and the stability of the financial system. These comprehensive documents outline a banking organization’s detailed strategy for an orderly resolution under the U.S. Bankruptcy Code or other applicable insolvency frameworks in the event of material financial distress or an outright failure. By requiring institutions to map out their own wind-down procedures, regulators aim to ensure that a major financial firm can be dismantled or restructured without requiring extraordinary government intervention, taxpayer-funded bailouts, or causing systemic contagion across global financial markets.

The recent evaluation involved a rigorous, joint review process conducted by both the FDIC and the Federal Reserve Board. The scope of this year’s assessment covered the 2025 resolution plan submissions provided by 15 distinct banking organizations, each holding more than $250 billion in total assets. This threshold targets the nation’s largest and most complex financial institutions, whose scale and interconnectedness demand heightened regulatory oversight and meticulous contingency planning to safeguard domestic and international economic stability.

In addition to evaluating the current round of submissions, the regulatory agencies also provided an update on past remediation efforts. Specifically, the FDIC and the Federal Reserve Board formally determined that a shortcoming previously identified in the 2021 resolution plan submitted by BNP Paribas has been satisfactorily addressed. This determination closes out the outstanding concerns regulators had previously noted regarding that institution’s recovery and resolution frameworks, reflecting a successful remediation process by the bank to meet federal standards.

The publication of these feedback letters underscores the ongoing commitment of U.S. financial regulators to transparency and rigorous oversight in the post-financial-crisis regulatory landscape. Living wills have evolved into a cornerstone of macroprudential policy since their implementation under the Dodd-Frank Wall Street Reform and Consumer Protection Act. By compelling large banking institutions to continuously evaluate their corporate structures, interconnections, critical operations, and funding mechanisms, regulators and bank management teams alike can better identify vulnerabilities before they manifest as systemic threats.

As the financial sector continues to navigate complex domestic and global economic environments, the requirement for robust, credible resolution plans remains a vital safeguard. The clean bill of health given to the 15 institutions in this latest review cycle indicates that large banking organizations are maintaining high standards of preparedness and strategic planning when it comes to managing severe financial distress. Both the FDIC and the Federal Reserve Board will continue to monitor these institutions closely and review future submissions to ensure that the U.S. banking system remains resilient, transparent, and prepared for unforeseen economic challenges.