WASHINGTON — The Federal Deposit Insurance Corporation and the Federal Reserve Board on September 29, 2026, published feedback letters for resolution plans submitted in October 2025 by 15 large banking organizations, stating that the joint review did not identify any shortcomings or deficiencies in the filings.

The announcement was issued as a joint press release, for release at 4:00 p.m. EDT. It covers the 2025 cycle of resolution plan submissions from banking organizations with more than $250 billion in assets. Feedback letters are the vehicle through which the agencies communicate the outcome of a review cycle to the organizations whose plans they examined.

Resolution plans, also known as living wills, describe a banking organization's strategy for orderly resolution in the event of material financial distress or failure. Under the Dodd-Frank Wall Street Reform and Consumer Protection Act, large banking organizations are required to submit these plans to the FDIC and the Federal Reserve, which conduct joint reviews of the filings. The review does not always end without findings: the same process previously surfaced a shortcoming in BNP Paribas' 2021 plan, which frames this cycle's findings-free result for the largest firms' wind-down blueprints.

In addition to reviewing the 2025 submissions, the agencies determined that the shortcoming previously identified in the 2021 BNP Paribas resolution plan has been satisfactorily addressed — the only prior finding named in the release, and a working example of how an issue raised in one cycle can be cleared in a later review.

The two agencies published individual feedback letters for the following five organizations:

• American Express Company 2025 Resolution Plan Feedback Letter (PDF)
• Barclays PLC 2025 Resolution Plan Feedback Letter (PDF)
• BNP Paribas 2025 Resolution Plan Feedback Letter (PDF)
• Deutsche Bank AG 2025 Resolution Plan Feedback Letter (PDF)
• UBS Group AG 2025 Resolution Plan Feedback Letter (PDF)

The individually named group is transatlantic: American Express is the only U.S.-headquartered firm among the five, joined by Barclays PLC of the United Kingdom, BNP Paribas of France, Deutsche Bank AG of Germany and UBS Group AG of Switzerland — a mix that reflects how far U.S. resolution planning requirements extend beyond domestically headquartered organizations.

The release also includes a template letter addressed to Category II and III firms with resolution plans due in October 2025. Those categories are part of the Federal Reserve's tailoring framework, which aligns enhanced prudential requirements with a firm's size and risk profile. In practice, the same October 2025 cycle spanned both regulatory tiers, with individual letters for some organizations and a standardized letter covering others.

For readers following the program, the markers to watch in future cycles are whether reviews again close without named findings and how feedback is delivered across the tailoring categories, with the 2021-to-2026 BNP Paribas arc as the reference point for how a flagged plan is resolved.

The full joint press release is available on the Federal Reserve Board's website, and details of the Board's action are published on its Board Votes page.