The Federal Reserve and FDIC published feedback letters Monday for 15 banking organizations with over $250 billion in assets, finding no shortcomings or deficiencies in their 2025 resolution plan submissions. The agencies also confirmed BNP Paribas has resolved a shortcoming identified in its 2021 plan.
Key Takeaways
- Fed and FDIC found no shortcomings in 2025 resolution plans for 15 banks with >$250B assets
- BNP Paribas resolved a shortcoming from its 2021 submission
- Six firms named: American Express, Barclays, BNP Paribas, Deutsche Bank, UBS; nine others unnamed
- Template letter issued for Category II/III firms outlining future expectations
- Clean reviews support confidence in resolvability of systemically important banks
Executive Intelligence Brief
Joint Review Clears All 15 Submissions
The Federal Deposit Insurance Corporation and the Federal Reserve Board conducted a joint review of resolution plans submitted in October 2025 by 15 banking organizations exceeding the $250 billion asset threshold. Known as living wills, these plans describe each firm's strategy for orderly resolution in the event of material financial distress or failure.
The agencies identified no shortcomings — a less severe designation than a deficiency — in any of the 15 submissions. The six firms explicitly named in the release are American Express Company, Barclays PLC, BNP Paribas, Deutsche Bank AG, and UBS Group AG. The remaining nine firms were not individually identified in the press release.
BNP Paribas Resolves Prior Shortcoming
In a notable development, the agencies determined that a shortcoming previously identified in BNP Paribas' 2021 resolution plan has been satisfactorily addressed. The specific nature of the 2021 shortcoming was not disclosed in the release. A shortcoming indicates a weakness in the plan that does not rise to the level of a deficiency, which would require a formal corrective action plan and could trigger regulatory restrictions.
Regulatory Framework and Tiered Expectations
Resolution plan requirements are tiered by asset size and systemic importance. Category I firms (typically U.S. GSIBs) and foreign-based Category II firms like those reviewed here submit full resolution plans on a biennial cycle. The agencies also issued a template letter to Category II and III firms with resolution plans due in October 2025, outlining supervisory expectations for future submissions.
The absence of deficiencies across this cohort suggests the post-2008 resolution planning framework — designed to ensure large banks can be wound down without taxpayer bailouts or systemic disruption — is functioning as intended for the largest and most complex institutions.
Market Implications and Forward Outlook
For creditors and counterparties, the clean feedback letters reduce uncertainty around the resolvability of these systemic institutions, potentially lowering funding costs and supporting confidence in derivative netting and collateral arrangements. The next full submission cycle for these firms will follow the standard biennial schedule, with interim updates typically required annually. Market participants should monitor the individual feedback letters, published as PDFs on the agencies' websites, for firm-specific guidance on areas for continued improvement.
