06/25/2026 | Press release | Distributed by Public on 06/25/2026 13:11
Earlier this month, I spoke about the challenges associated with resolving large insured depository institutions (IDIs) and the utility of advance preparedness.1 In addition, I have long been critical of the way the FDIC has historically approached resolution planning for such institutions,2 which has taken the form of lengthy narrative plans, rather than focusing on the key information the FDIC needs to execute a resolution and on maximizing the likelihood of an optimal resolution outcome.
Today, the Board is considering a proposed rule that would meaningfully adjust our approach to IDI resolution submissions by substantially streamlining filing requirements to focus on the operational information most relevant for the FDIC. In addition, the proposed rule would, among other things, (1) raise the asset threshold for determining applicability from $50 billion to $100 billion and provide for automatic future adjustments; (2) establish a three-year filing cycle for all covered IDIs and eliminate interim supplements; and (3) eliminate credibility determinations.3
I would like to thank the FDIC staff for their work on this proposed rule, and I also want to thank Comptroller Gould for his constructive engagement on resolution planning issues over the past several months. I look forward to comments on the proposal.
| 1 | See Travis Hill, Rethinking Resolution Readiness: Learning from Experience and Sharpening Focus (June 9, 2026) ("By contrast [to a bank failure where the failed bank is relatively small and simple and the FDIC has a runway leading up to failure], advance planning is particularly valuable when neither of those characteristics is present: the institution is not small and simple, and the FDIC has a short or nonexistent runway. Additionally, larger institutions are more likely to fail with shorter runways, given greater public scrutiny and a higher likelihood of liquidity-induced failures. In these cases, analyzing and understanding a bank's systems, infrastructure, and data in order to market and sell the institution is very difficult in a short period of time, given the volume and complexity of data sets and IT systems."). |
| 2 | See, e.g., id. ("…the FDIC's historical approach to resolution planning for large [IDIs] needs to be fundamentally reexamined, reoriented, and rationalized."). |
| 3 | This proposal is being considered in conjunction with a separate proposal that would amend our assessment framework to provide a "resolution readiness adjustment" for which all institutions subject to the IDI Rule would be eligible. See Federal Deposit Insurance Corporation, Assessment Thresholds, Rate Schedules, and Adjustments (June 25, 2026). |