The Federal Deposit Insurance Corporation and the Federal Reserve Board have published feedback letters regarding resolution plans submitted by 15 banking organizations in October 2025. The agencies conducted a joint review of these submissions, which are required for firms with more than $250 billion in assets, and determined that none contained shortcomings or deficiencies.
Resolution plans, often referred to as living wills, outline strategies for orderly resolution during material financial distress or failure. Among the reviewed entities were American Express Company, Barclays PLC, BNP Paribas, Deutsche Bank AG, and UBS Group AG. Additionally, the agencies confirmed that a shortcoming previously identified in BNP Paribas's 2021 resolution plan has been satisfactorily addressed.
The absence of identified deficiencies across all 15 major banking organizations signals a maturation in the post-crisis regulatory framework governing systemic risk management. By clearing these institutions without requiring remedial actions, the FDIC and Federal Reserve indicate that the current standards for planning orderly resolutions have been effectively integrated into the operational structures of these large banks. This outcome reduces immediate regulatory friction for Category II and III firms, allowing them to focus on execution rather than iterative compliance adjustments.
For institutional stakeholders, the satisfactory resolution of the prior BNP Paribas deficiency demonstrates the efficacy of the supervisory feedback loop. It suggests that when regulators identify specific gaps, targeted remediation is achievable within a reasonable timeframe. However, the uniformity of this clean assessment may also prompt scrutiny regarding whether the criteria for 'no shortcomings' remain sufficiently rigorous as market conditions evolve. Continued monitoring will be essential to ensure that these static approvals do not mask emerging vulnerabilities in cross-border liquidity or complex derivative unwinding scenarios.
