FDIC modifies resolution planning for large banks

The FDIC modified its approach to resolution planning for large banks.

Details: The FDIC said the purpose of the action is to focus on the operational information most relevant for the FDIC to resolve a large bank through a weekend sale or operate the institution for a short period of time while rapidly marketing the institution.

Changes: For full resolution submissions during the upcoming submission cycle, the FDIC said it has exempted banks from certain content requirements, such as utilizing a bridge bank strategy and a hypothetical failure scenario in the plan.

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.

FAQs: The FDIC also issued an updated set of frequently asked questions describing the exemptions and clarifying certain expectations.

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.