Published:
Agencies publish resolution plan feedback letters for 15 banking organizations
The FDIC and the Federal Reserve Board published feedback letters on 2025 resolution plans for 15 large banks and said they did not identify shortcomings in the submissions. They also said a previously identified issue in the 2021 BNP Paribas resolution plan has been addressed.
The FDIC and the Federal Reserve Board published feedback letters for resolution plans (“living wills”) submitted in October 2025 by 15 banking organisations with more than $250 billion in assets. In the agencies’ review, they stated that they did not identify any shortcomings or deficiencies in the resolution plan submissions.
The release frames resolution plans as contingency strategies describing how a banking organisation would be resolved in the event of material financial distress or failure. As part of the same review, the agencies also noted that a shortcoming previously identified in the 2021 BNP Paribas resolution plan has been satisfactorily addressed.
For FX traders, the main implication is the risk backdrop for the US financial system. When regulators indicate that large banks’ resolution planning is in good order, it can reduce perceived risks around the possibility of disorderly outcomes, which can support financial conditions through lower perceived credit and liquidity stress.
What to watch next is whether future resolution-plan reviews introduce new shortcomings for any major institutions, or whether additional regulatory communications shift expectations about the resilience of large-bank resolution frameworks.
Why this matters for FX
Resolution-plan feedback is relevant for FX mainly through financial stability and funding/credit-risk expectations. A finding of “no shortcomings or deficiencies” on multiple large banks can be read as reducing perceived tail-risk of disorderly resolution, which typically supports broader risk sentiment and financial conditions. For USD FX, that can matter via changes in sovereign/bank risk premia and expectations for stress in the financial system, even though it is not a direct monetary-policy signal.