Agencies publish resolution plan feedback letters for 15 banking organizations
WASHINGTON — In a joint regulatory update released Monday afternoon at 4:00 p.m. Eastern Daylight Time, the Federal Deposit Insurance Corporation (FDIC) and the Federal Reserve Board announced the official publication of feedback letters concerning the resolution plans submitted by major financial institutions in October 2025. According to the federal regulatory agencies, a comprehensive evaluation of the submissions revealed a clean bill of health, with officials confirming that no shortcomings or deficiencies were identified in any of the resolution plan submissions evaluated during this review cycle.
The announcement marks a significant milestone for the 15 banking organizations subject to the review, all of which maintain substantial asset portfolios exceeding the $250 billion threshold. These institutions are systematically required to draft and submit detailed strategic blueprints—commonly referred to in the financial sector as "living wills"—that outline comprehensive strategies for an orderly resolution, restructuring, or winding down of operations in the hypothetical event of severe material financial distress or outright corporate failure.
The requirement for living wills emerged as a cornerstone of post-financial crisis regulatory reform, designed specifically to prevent systemic contagion and avoid the chaotic, taxpayer-funded bailouts that characterized previous eras of economic instability. By compelling major financial institutions to meticulously map out their interconnections, critical operations, legal entity structures, and core business lines well in advance, federal regulators ensure that these mega-banks can be safely resolved under the U.S. Bankruptcy Code or alternative statutory frameworks without imposing catastrophic disruptions on the broader financial system or the wider economy.
The joint review conducted by the FDIC and the Federal Reserve Board focused intensely on the strategic feasibility, operational readiness, and overall credibility of the plans submitted late last year. Because institutions holding upwards of $250 billion in assets represent critical pillars of domestic and international commerce, the rigorous scrutiny applied by banking authorities is designed to verify that these firms possess the internal mechanisms necessary to ring-fence assets, maintain continuous operational services, and provide timely, accurate data to regulators during a crisis scenario. The absence of any identified shortcomings or deficiencies in the latest round of submissions indicates that the targeted institutions have successfully aligned their operational architectures and contingency planning with the heightened expectations established by federal oversight bodies.
In addition to evaluating the most recent submissions from the group of 15 major banking organizations, the federal regulators also provided an important update regarding the compliance status of foreign banking organizations operating within the United States. Specifically, the agencies formally determined that a shortcoming that had been previously identified in the 2021 resolution plan submitted by BNP Paribas has now been fully and satisfactorily addressed.
The resolution of the past concern regarding BNP Paribas highlights the iterative and collaborative nature of the living wills process. When regulators identify a shortcoming during their multi-layered evaluations, affected banking organizations are typically required to take corrective actions, refine their analytical methodologies, or enhance their operational capabilities to bridge identified gaps. The official sign-off confirming that BNP Paribas has successfully resolved its historic deficiency underscores the ongoing engagement between international financial institutions and U.S. regulators to ensure robust, uncompromised preparedness across the entire spectrum of large-scale banking operations.
Monday’s publication of the feedback letters provides both the marketplace and the participating institutions with transparent insight into the current posture of systemic risk management. By publicly releasing these assessments, the Federal Deposit Insurance Corporation and the Federal Reserve Board continue to foster accountability and market discipline within the domestic banking sector, ensuring that financial institutions maintain a posture of constant vigilance and preparedness against unexpected economic headwinds and market volatility.
