Notice of Proposed Rulemaking to Amend the Rule Requiring Resolution Submissions by Covered Insured Depository Institutions

Summary:

On June 25, 2026, the FDIC Board of Directors (Board) approved a notice of proposed rulemaking that would revise the resolution submission requirements that currently apply to insured depository institutions (IDIs) with $50 billion or more in total assets (IDI Rule). Among other things, the proposal would significantly streamline filing requirements to focus on the information that most directly supports the FDIC's readiness to resolve the institution in a cost-effective manner; raise and index the dollar threshold that determines the scope of applicability; eliminate requirements to provide extensive narratives and analyses, such as those related to hypothetical resolution strategies and scenarios; and eliminate the FDIC's credibility determinations of submissions.

In light of the ongoing rulemaking process, the Board exempted all IDIs subject to the IDI Rule from filing requirements in October 2026 and in 2027.

Statement of Applicability: Insured depository institutions with $50 billion or more in total assets.

Highlights:

• The proposal would raise the dollar threshold determining whether an IDI is subject to the IDI Rule from $50 billion to $100 billion as of the effective date of the final rule and provide for automatic future adjustments pursuant to an indexing methodology.
• The proposal would move all covered IDIs to a three-year cycle for filing resolution submissions, and information on material changes would be obtained through notices of extraordinary events, rather than by relying on interim supplements.
• The proposal would eliminate more than half of the IDI Rule's content requirements, such as resolution-related hypothetical analyses and content regarding strategy, optionality, challenges, and mitigating actions in resolution relevant to the FDIC's resolution responsibilities.
• The proposal also would eliminate expectations for, and descriptions of, the covered IDI's capabilities, as well as capabilities testing under the IDI Rule.
• The proposal would eliminate the public section of the submission, reflecting the shift away from analyses and strategy generated by covered IDIs to operational information relevant for FDIC resolution preparedness.
• The proposal would eliminate the FDIC's credibility determinations and the approach to feedback (i.e., identifying "material weaknesses" or "significant findings," as described in the IDI Rule).
• The proposal would maintain, with certain revisions, key informational content requirements such as financial information; corporate structure; key personnel; and information systems.
• The proposal would add new aspects to certain content requirements to enhance the FDIC's ability to plan and execute a resolution, including information to better understand the covered IDI's organization; a mapping of the covered IDI's information technology architecture; and certain information on deposit activities and qualified financial contracts.
• The proposal would implement a transition such that initial submissions under the final rule would be due no earlier than 270 days after the final rule's effective date.
• Comments on the proposal will be accepted for 60 days after publication in the Federal Register. A proposal for a Resolution Readiness Adjustment as part of the deposit insurance assessment framework is being published separately and concurrently for notice and comment.