FDIC Staff Updates Resolution Planning Guidance

The FDIC updated its guidance for insured depository institutions subject to resolution planning requirements ("IDIs") ahead of submissions due July 1, 2025.

According to an accompanying press release, the "purpose" of the update "is to focus the IDI resolution planning process on the operational information most relevant for the FDIC to (1) resolve a large bank through a weekend sale or (2) operate the institution for a short period of time while rapidly marketing the institution." For the next round of submissions, the FDIC said that it "exempted IDIs from certain content requirements, such as the requirements to utilize a bridge bank strategy and a hypothetical failure scenario in the plan."  

The revised FAQs address, among other topics, the FDIC's expectations on content requirements for 2025 resolution plans under the resolution planning rule for submissions and operational capabilities as to both group A (CIDIs with more than $100 billion in total assets) and group B CIDIs (CIDIs with at least $50 billion but less than $100 billion in total assets). The updates also clarify distinctions between the two groups and the appropriate application of guidance in specific areas.

In the FAQs, the FDIC stated that group B CIDIs are not required to provide "separability" content in their 2025 submissions. However, a group B CIDI may include such information voluntarily. Group A CIDIs, in contrast, must address separability in accordance with the 2021 Statement of Policy ("SOP").

On resolution-related capabilities, the FDIC clarified that certain capabilities required under the 2021 SOP—such as the capability to support the transfer of a franchise or facilitate the sale of a business line—apply only to group A CIDIs. Group B CIDIs are only required to describe how their existing capabilities support their plan's strategy and optionality.

The FDIC further explained that group B CIDIs are not expected to submit a separate business line analysis or valuation analysis unless such content is necessary to support their plan’s strategic options. In contrast, group A CIDIs must provide such analyses, consistent with the SOP.

The updated FAQs also confirm that all CIDIs must comply with the July 1, 2025 deadline, regardless of their group designation, and that institutions may not rely on previously submitted content unless expressly permitted by the FDIC.