Agencies publish resolution plan feedback letters for 15 banking organizations
WASHINGTON — In a joint regulatory announcement released Monday afternoon at 4:00 p.m. Eastern Daylight Time, the Federal Deposit Insurance Corporation (FDIC) and the Federal Reserve Board made public their official feedback letters regarding the latest round of resolution plans submitted by major financial institutions.
According to the regulatory agencies, the comprehensive joint review of the resolution plans submitted in October 2025 by 15 major banking organizations yielded positive results. Federal regulators confirmed that they did not identify any shortcomings or deficiencies in these crucial submissions, signaling a clean bill of health for the participating institutions regarding their emergency preparedness and structural wind-down strategies.
The reviewed submissions apply specifically to large banking organizations holding more than $250 billion in total assets. These institutions are subject to stringent federal oversight designed to safeguard the broader financial system against systemic contagion, unexpected insolvency events, and disorderly market disruptions.
Resolution plans, which are commonly referred to within the financial sector as "living wills," serve as foundational documents for large banking organizations. These detailed blueprints outline an institution’s comprehensive strategy for an orderly resolution under applicable insolvency laws in the event of material financial distress or outright failure. By mapping out critical operations, interconnected legal entities, funding mechanisms, and core business lines well in advance, living wills are intended to provide regulators and market participants with a clear roadmap for dismantling or restructuring a troubled firm without necessitating a taxpayer-funded bailout or creating widespread economic panic.
The recent joint evaluation represents a significant milestone in the ongoing oversight of the United States banking sector. The transition from previous compliance challenges to a clean review cycle across 15 major institutions highlights the substantial investments these banking organizations have made in risk management, operational resilience, and regulatory compliance infrastructure over recent years.
In addition to evaluating the 2025 submissions from the primary cohort of large institutions, the Federal Deposit Insurance Corporation and the Federal Reserve Board also provided an important update regarding historical enforcement matters. The regulatory agencies formally determined that a shortcoming previously identified in the 2021 resolution plan submitted by BNP Paribas has now been satisfactorily addressed.
The closure of the legacy finding for BNP Paribas marks the successful resolution of concerns that federal regulators had previously flagged during earlier review cycles. It demonstrates the iterative and collaborative nature of the supervisory process, wherein large foreign and domestic banking organizations work closely with U.S. regulators to remediate structural vulnerabilities and align their operational frameworks with regulatory expectations.
The publication of these feedback letters underscores the continued commitment of both the Federal Deposit Insurance Corporation and the Federal Reserve Board to transparency and rigorous oversight within the national banking system. By making these evaluations publicly available, the agencies provide market participants, analysts, and the public with insight into the financial health and structural preparedness of the nation’s most systemically important banking organizations.
As the financial regulatory landscape continues to evolve in response to global economic shifts and emerging market risks, the submission, review, and public reporting of resolution plans remain central pillars of macroprudential policy. The absence of identified deficiencies in the latest round of filings indicates that the banking sector’s largest players maintain robust frameworks to manage severe financial distress, reinforcing stability across domestic and international markets.
