The Federal Deposit Insurance Corporation and the Federal Reserve Board released feedback letters Tuesday afternoon for the resolution plans filed in October 2025 by 15 of the largest banking organizations in the country. The agencies found no shortcomings or deficiencies in any of the submissions. The letters were published at 4:00 p.m. EDT.
Resolution plans, commonly called living wills, lay out how a bank holding company would be wound down in an orderly fashion if it hit material financial distress or failed outright. Section 165(d) of the Dodd-Frank Wall Street Reform and Consumer Protection Act requires bank holding companies with $250 billion or more in consolidated assets — plus certain firms between $100 billion and $250 billion, and any designated nonbank financial company — to file these plans with regulators.
The agencies reviewed the 2025 filings from the 15 organizations subject to the October 2025 cycle. In the same release, the FDIC and the Fed said the shortcoming previously flagged in BNP Paribas's 2021 resolution plan has been satisfactorily addressed.
Not every regulator went along. According to <>Crowdfund Insider, Comptroller of the Currency Jonathan V. Gould issued a statement explaining his vote against the joint resolution plan letter sent to American Express, and he reaffirmed the need for reforms to Dodd-Frank Act Section 165(d). The Fed-FDIC release does not detail the basis for Gould's dissent, and his statement does not appear in the joint press materials.
Who Got the Letters
Five firms received individual feedback letters, according to <>Securities.io: American Express Company, Barclays PLC, BNP Paribas, Deutsche Bank AG and UBS Group AG. The remaining ten Category II and III firms with plans due the same month received a template letter. That group includes Bank of Montreal, Mizuho Financial Group, Mitsubishi UFJ Financial Group, Northern Trust Corporation, The PNC Financial Services Group, Royal Bank of Canada, Sumitomo Mitsui Financial Group, The Toronto-Dominion Bank, Truist Financial Corporation and U.S. Bancorp.
Under the jointly issued Resolution Plan Rule, a triennial full filer submits a plan every three years, alternating between full and targeted plans. Section 165(d) allows the agencies to jointly determine that a plan is not credible or would not facilitate an orderly resolution under Title 11 of the U.S. Bankruptcy Code. That determination is what the review process is built to catch. In this cycle, for these 15 institutions, the agencies made no such finding.
Firms submitted the plans on or before October 1, 2025. The feedback letters released Tuesday are the public record of how the agencies assessed them.
Eight of the 15 firms receiving letters operate under foreign parent companies — Barclays, BNP Paribas, Deutsche Bank, UBS, Bank of Montreal, Mizuho, Mitsubishi UFJ, Royal Bank of Canada, Sumitomo Mitsui and Toronto-Dominion — but each files because it meets the U.S. asset threshold under the rule. That means the failure-planning architecture being signed off on covers a substantial slice of the global banking firms with major American operations.
The Gap in the Record
What the feedback letters themselves say about each institution has not been spelled out in the agencies' release. The joint statement describes the outcome — no shortcomings, no deficiencies — but the substance of any supervisory expectations attached to the letters is contained in the individual documents, which the agencies posted alongside the announcement.
The agencies maintain that resolution planning is a forward-looking exercise. The purpose of a living will is to prove in advance that a failing megabank can be taken apart without a taxpayer rescue. The credibility review is the gate. When the gate opens without objection for 15 firms at once, the question of how demanding that gate actually is becomes a fair one for the public paying for the backstop.
Comptroller Gould's dissent on American Express is the only recorded break from the joint position in Tuesday's release. The Office of the Comptroller of the Currency has not published a full account of his reasoning in the agencies' joint materials.
Read together with the BNP Paribas note, the message from the FDIC and the Fed is that the largest banks are prepared for their own failure. The public cost of that confidence is the continued existence of the federal safety net standing behind them.
Our Take
Fifteen banks with more than $250 billion in assets each. Zero shortcomings. Zero deficiencies. A clean sweep from the same agencies that are supposed to be the last line of defense between a bank collapse and a taxpayer-funded rescue. Patriots, ask yourself the obvious question: what exactly is the review for if everyone passes?
None of this is new. The living will process has been a compliance ritual for years — a mountain of paperwork, a small army of consultants, and a regulator that almost never says no. The whole point of Dodd-Frank's resolution authority was to end too-big-to-fail. Instead we got too-big-to-review. The banks submit their plans, the agencies nod, and the implicit guarantee stays exactly where it was.
The one shred of accountability in Tuesday's release came from Comptroller Gould, who refused to sign off on the American Express letter and used the moment to say out loud what everyone in Washington knows: Section 165(d) needs reform. He is right. A process where the answer is always yes is not oversight. It is theater.
And notice what the release does not tell you. It does not tell you what the letters actually require of these banks. It does not tell you whether any of these firms have exposure that would test the plan in a real crisis. It tells you the paperwork was fine. That is not the same thing as saying the banks are safe — and the American people deserve to know the difference before the next crisis, not after the next bailout.
If your congressman is not asking why 15 megabanks passed unanimously while the Comptroller himself dissented, call his office and ask. The living wills are supposed to be for us. It is past time the regulators acted like it.
