What the agencies published

The Federal Deposit Insurance Corporation and the Federal Reserve Board published feedback letters on September 29, 2026 for the resolution plans that 15 large banking organizations submitted in October 2025, and found no shortcomings or deficiencies in them.

The finding is the substance of the announcement. Agencies can and do identify shortcomings in these plans, which then obliges the firm to address them, so a clean review of an entire filing cohort says something about the state of the plans rather than being a formality.

What a resolution plan is

A resolution plan, also called a living will, describes a banking organization's strategy for being resolved in an orderly way if it suffers material financial distress or fails.

The idea is that a large bank should be able to fail without a taxpayer rescue, and that the plan should show how its parts could be separated, sold or wound down. That is a planning exercise rather than a prediction, and the regulator's review tests whether the plan is credible.

A generic plan document labeled “LIVING WILL” branches to three abstract organizational pathways.
Concept diagram: a resolution plan can describe options for separating, selling or winding down discrete operations in an orderly resolution; it is not a specific bank plan or a failure forecast.

Who was covered

The review covered the October 2025 submissions from 15 banking organizations with more than $250 billion in assets.

That threshold matters for anyone tracking which firms are in scope, because the resolution planning requirement applies to institutions by size and category rather than by name. The agencies conducted the review jointly, which is why the release is issued by both.

Five individual feedback letters are published on the release page: American Express Company, Barclays PLC, BNP Paribas, Deutsche Bank AG and UBS Group AG. The agencies also published a template letter sent to Category II and III firms whose resolution plans were due in October 2025.

The BNP Paribas detail

The agencies said BNP Paribas had satisfactorily addressed the shortcoming identified in its 2021 resolution plan. The finding closes an issue the firm has worked on over several years.

It also shows how to read the rest of the cohort's result. A no-shortcomings finding for the 2025 submissions does not mean earlier issues never existed; it means the plans reviewed in this cycle did not present new ones the agencies considered unresolved.

Why the finding is unusual enough to report

Resolution plan reviews do not normally produce zero findings across a large group, which makes this announcement short but informative.

For the firms involved, a clean review removes one supervisory task from the near-term list. For anyone watching the resolution framework, the result is a data point about how the plans have matured since the requirement was introduced, at least as the agencies assess them now.

The announcement does not quantify that maturity or compare this cohort with earlier ones, and it does not explain what the agencies reviewed in each plan. Those judgements sit in the letters themselves.

What the release does not say

The announcement does not summarize the contents of any individual letter, describe how the plans differ from each other, or say whether the agencies considered one firm's plan stronger than another's.

It also does not set out the next filing cycle or say when the next set of plans is due, and it gives no view on whether the resolution framework itself needs changes.

For anyone who wants the detail, the letters are the primary documents, and five of them are published as PDFs on the release page alongside the template letter.

How to read it if you follow a specific bank

The practical approach is direct. Check whether the firm in question is in the cohort of 15 organizations with more than $250 billion in assets that filed in October 2025, then look for its letter among the published PDFs.

If the letter is not among the five published examples, the finding for that firm is still covered by the joint statement that no shortcomings or deficiencies were identified in the submissions reviewed, and the template letter shows the format the agencies used for Category II and III firms.