Federal regulators issue resolution plan feedback letters for 15 banking organizations

WASHINGTON — Federal regulators published joint resolution plan feedback letters on Sept. 29, 2026, directing 15 major banking organizations to address identified shortcomings in their winding-down strategies under the Dodd-Frank Act. The Federal Reserve Board and the Federal Deposit Insurance Corporation released the evaluations to ensure that large financial institutions can be resolved under the U.S. Bankruptcy Code without systemic disruption or taxpayer-funded bailouts.

Strategic Context

Under Title I of the Dodd-Frank Wall Street Reform and Consumer Protection Act, large financial institutions are required to submit periodic living wills detailing how they would manage a rapid and orderly failure under financial distress. The regulatory agencies review these plans to evaluate whether the banks have established operational structures capable of separating core functions, maintaining critical services, and protecting financial stability during a crisis.

The feedback letters provide formal supervisory determinations on the adequacy of the submissions from the 15 covered banking organizations. When agencies identify deficiencies or shortcomings during their review, institutions are required to adjust their operational models, legal entity structures, or data-sharing capabilities to satisfy statutory expectations.

Forward Outlook

The banking organizations that received feedback must incorporate the regulatory directives into their upcoming resolution planning cycles. Compliance officers, legal teams, and risk executives at the affected institutions will review the specific supervisory critiques to determine required adjustments to capital allocation, operational continuity agreements, and inter-affiliate dependencies as detailed by the Federal Reserve.