US regulators find no shortcomings in 15 large banks’ resolution plans
The Federal Reserve and FDIC published feedback on plans submitted in October 2025 and said none contained a shortcoming or deficiency. The finding does not test how a plan would work in a failure.
The Federal Reserve and Federal Deposit Insurance Corporation said on September 29, 2026, that they found no shortcomings or deficiencies in resolution plans submitted by 15 banking organizations with more than $250 billion in assets in October 2025. The US regulators published feedback letters on the plans, which set out how the organizations would seek an orderly resolution if they faced severe financial distress or failure.
The finding covers the submissions reviewed in this cycle. The agencies’ announcement gives an overall result but does not set out each organization’s detailed feedback in its text. It therefore establishes the regulators’ assessment of the submitted plans, without showing that a proposed strategy has worked during an actual bank failure.
What the regulators said about the 2025 plans
The Federal Reserve and FDIC described the plans, commonly called living wills, as strategies for resolving a banking organization in an orderly way if it enters material financial distress or fails. Their joint review covered plans submitted in October 2025 by 15 organizations above the $250 billion asset threshold. The agencies said they identified neither shortcomings nor deficiencies in those submissions.
The announcement also dealt with an earlier finding involving BNP Paribas. The regulators said a shortcoming they had identified in the bank’s 2021 resolution plan had been satisfactorily addressed. That is a separate statement about an older plan, alongside the overall assessment of the October 2025 submissions.
The release links feedback letters for several named organizations, including American Express, Barclays, BNP Paribas, Deutsche Bank and UBS, as well as a template letter for certain firms. Its accessible announcement text does not identify all 15 reviewed organizations or describe any institution-specific requests in those letters. The public finding should therefore be read as the agencies’ collective result for the review, rather than a summary of every point raised with each firm.
Why banks prepare living wills
Resolution planning asks a large banking organization to set out a route through a potential failure before that failure occurs. In an October 2025 speech, then-FDIC Acting Chairman Travis Hill explained that plans filed under Title I of the Dodd-Frank Act address the whole banking organization, contemplate resolution under the US Bankruptcy Code and focus on financial stability and systemic risk.
Hill distinguished those plans from a separate FDIC requirement for large insured depository institutions. Those institution-level plans focus on operational execution under the Federal Deposit Insurance Act. The distinction matters when reading the new announcement: a finding about the reviewed banking-organization submissions should not be taken as a finding about every separate resolution-planning requirement that may apply to a bank.
A public resolution plan filed by Bank of Montreal illustrates the kind of operational detail such planning can involve. Its hypothetical US strategy describes possible FDIC receivership for bank subsidiaries, a potential transfer of assets and liabilities to a bridge bank, and continued access to technology, staff, facilities and suppliers. The bank’s plan says its assumptions are hypothetical and do not bind a bankruptcy court or resolution authority.
How the finding compares with the 2024 review
The agencies reported a different result in June 2024 after reviewing plans submitted in July 2023 by eight of the largest and most complex banks. They identified weaknesses in the plans of Bank of America, Citigroup, Goldman Sachs and JPMorgan Chase, while finding no weaknesses in the other four plans in that review.
For Bank of America, Goldman Sachs and JPMorgan Chase, the agencies jointly classified the weaknesses as shortcomings. They also jointly identified a weakness in Citigroup’s plan but differed over its severity. According to the 2024 announcement, the four banks were expected to address the weaknesses in their next plans, due July 1, 2025. Those earlier findings concerned a different submission cycle and review group; they are context for the regulators’ terminology, not findings about the 15 plans announced on September 29.
Sources and context
- Agencies publish resolution plan feedback letters for 15 banking organizationsFederal Reserve Board and Federal Deposit Insurance Corporation
- 2025 165(d) Resolution Plan Public Section — BMO U.S.Bank of Montreal
- Resolution Readiness and Lessons Learned from Recent Large Bank FailuresFederal Deposit Insurance Corporation; speech by Acting Chairman Travis Hill
- Agencies Announce Results of Resolution Plan Review for Largest and Most Complex BanksFederal Deposit Insurance Corporation and Federal Reserve Board
AI-assisted article checked against the listed sources. NewsJaws did not conduct interviews or attend the reported events.
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