September 29, 2026

Agencies publish resolution plan feedback letters for 15 banking organizations

WASHINGTON — In a joint regulatory update issued on Monday afternoon, the Federal Deposit Insurance Corporation and the Federal Reserve Board announced the release of feedback letters regarding resolution plans submitted by major financial institutions in October 2025. According to the federal regulatory agencies, the joint review of the submissions yielded positive results, with authorities identifying no shortcomings or deficiencies in the resolution plans provided by the 15 participating banking organizations.

The announcement, released publicly at 4:00 p.m. EDT, marks a significant milestone in the ongoing oversight of systemic financial institutions following the regulatory frameworks established in the wake of past global financial crises. Resolution plans, which are commonly referred to in the financial sector as "living wills," serve as critical regulatory documents. These plans are designed to outline a banking organization’s comprehensive strategy for an orderly resolution under the U.S. Bankruptcy Code or other applicable insolvency laws in the event of material financial distress or the ultimate failure of the institution.

The primary objective of requiring these detailed documents is to ensure that a failing institution can be wound down safely without necessitating a taxpayer-funded government bailout and without triggering broader contagion or systemic instability within the wider financial markets. The recent joint review conducted by the Federal Reserve Board and the Federal Deposit Insurance Corporation covered the 2025 resolution plan submissions specifically provided by banking organizations holding over $250 billion in consolidated assets. This asset threshold captures the nation’s largest and most complex domestic and foreign-affiliated financial institutions, whose operations are deeply intertwined with the global economy.

By successfully clearing this round of evaluations without receiving any notices of shortcomings or deficiencies, the 15 banking organizations have demonstrated that their strategic frameworks for potential distress scenarios meet the rigorous standards expected by U.S. regulators. These evaluations involve extensive analysis by agency staff, who scrutinize various aspects of the living wills, including operational continuity, governance structures, financial resource availability, and the feasibility of executing structural separations or asset sales under extreme stress.

In addition to clearing the 2025 submissions for the group of 15 major institutions, the federal regulatory agencies also provided an important update regarding international banking operations previously under closer scrutiny. Specifically, the Federal Reserve Board and the Federal Deposit Insurance Corporation formally determined that the shortcoming previously identified in the 2021 resolution plan submitted by BNP Paribas has been satisfactorily addressed.

The resolution of this past finding indicates that the institution has taken the necessary corrective actions and implemented structural or operational adjustments to satisfy regulatory expectations regarding its U.S. operations. The closure of this lingering deficiency reflects the continuous dialogue and remediation process that takes place between large banking organizations and their regulatory overseers to ensure compliance with heightened prudential standards.

The publication of these feedback letters underscores the ongoing commitment of both the Federal Deposit Insurance Corporation and the Federal Reserve Board to transparency and rigorous oversight in the supervision of systemically important financial institutions. As the financial landscape continues to evolve alongside shifting macroeconomic conditions, market participants and regulators alike view these regular resolution plan submissions and subsequent feedback mechanisms as essential tools for safeguarding the stability and resilience of the United States banking system.