Resolution planning requirements eased in 2025 will be proposed as permanent in 2026, agency informs

Banks with $50 billion or more in total assets will face in 2026 new resolution planning requirements designed to codify rules eased in 2025, the federal bank deposit insurance agency said Wednesday.

In a financial institution letter (FIL-63-2025), the Federal Deposit Insurance Corp. (FDIC) said it will propose next year changes to the insured depository institution regulation (IDI Rule) that, at a minimum, codify the content requirement exemptions and frequently asked questions (FAQs) associated with a modified approach set out in April 2025.

The agency noted that, in April, its board modified the approach to implementing the IDI Rule to focus on information “most relevant to conducting an effective resolution and to reduce burden on CIDIs by waiving content that required speculative analysis or information that was of relatively low value.” Those changes will be codified in next year’s proposal, the agency said.

“This shift reflected the prioritization of executing a large bank resolution through a weekend sale or, if necessary, operating the bank for a short period of time while rapidly marketing the institution or its assets,” the agency asserted. “These changes were applied to all IDI Rule submissions during the filing cycle that began in July 2025.”

The agency, in its FIL, said more changes will be proposed. Those will “take into account lessons learned from reviewing 2025 IDI Rule submissions to ensure that the information most critical to supporting the FDIC’s ability to execute a rapid, low-cost failed bank resolution under the FDI Act is available to the FDIC, while eliminating requirements that might distract from this objective or that otherwise provide relatively low value.”

In advance of the proposal, the agency said, the FDIC will continue to “evaluate the interplay between the Title I Rule, which requires certain bank holding companies to submit resolution plans to the FDIC and Federal Reserve Board, and the IDI Rule, and will consider adjustments to address overlap between these requirements.”

The FIL also outlines 2026 submission requirements and capabilities testing.

FDIC Provides Update on IDI Resolution Planning for Large Banks

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