Agencies release resolution plans for large banks

The Federal Reserve and FDIC released the public sections of resolution plans for the eight largest and most complex domestic banking organizations and 56 foreign banking organizations.

Details: The banks were required to submit resolution plans by July 1. The FDIC also released public sections of the resolution plans of 12 large insured depository institutions.

Prior Actions: The FDIC in April modified its approach to resolution planning for large banks. The agency also issued an updated set of frequently asked questions describing the exemptions and clarifying certain expectations.

Background: Under the FDIC’s resolution plan rule, banks with $100 billion or more in total assets are required to submit resolution plans, and banks with at least $50 billion but less than $100 billion in total assets are required to submit informational filings.

ICBA View: In a 2023 comment letter to the FDIC, ICBA said it agrees with resolution planning for banks with at least $100 billion in assets, but banks between $50 billion and $100 billon should generally be exempt.