The Federal Deposit Insurance Corporation and the Federal Reserve Board published feedback letters on Sept. 29 for the 2025 resolution plans of 15 large banking organizations, and the agencies found nothing to fix.
What happened
The two agencies reviewed plans submitted in October 2025 by 15 banking organizations with over $250 billion in assets. In the release, the agencies said they “did not identify any shortcomings or deficiencies in these resolution plan submissions.” They also determined that the shortcoming identified in BNP Paribas’s 2021 plan “has been satisfactorily addressed.”
The release links individual letters for American Express Company, Barclays PLC, BNP Paribas, Deutsche Bank AG and UBS Group AG, plus a template letter for Category II and III firms with plans due in October 2025. Resolution plans, also known as living wills, “describe a banking organization’s strategy for orderly resolution in the event of material financial distress or failure.”
Why it matters
A clean round means no firm in this group has a supervisory finding to remediate before its next submission. For finance leaders who depend on these banks as payment, custody or settlement counterparties, the letters are one of the few public, agency-signed statements about how a large bank would be wound down. They are worth reading next to the recent regional bank failure that tested the FDIC’s playbook.
Our read
The letters cover the plans banks filed in October 2025. They say nothing about what those banks have added since, such as bank-fintech partnerships, stablecoin settlement arrangements and tokenized deposits, which we have covered as bank regulators rewriting the rules for fintech partners. A no-findings letter sets the baseline for the next filing. The open question is whether the next plans map those newer dependencies.
Source: Federal Reserve Board
