The Federal Reserve, working alongside the nation's other bank regulators, published resolution plan feedback letters for 15 major banking organizations, putting on the record what supervisors have told the largest institutions about how they would be wound down in a crisis.
Resolution plans — commonly called "living wills" — are the blueprints big banks must file under the Dodd-Frank framework showing how they could be unwound in bankruptcy without a taxpayer bailout or a shock to the wider financial system. The newly published letters are the regulators' written responses to those plans for this batch of 15 firms.
The Fed's announcement comes with sharp limits on what it actually tells the public: the letters are feedback documents, not full agency judgments, and nothing in the release indicates any of the 15 institutions has been hit with a formal deficiency notice.
What the Letters Are — and What They Aren't
Resolution plan feedback letters typically spell out where a bank's wind-down strategy is credible, where examiners flagged gaps, and what the firm is expected to fix before the next filing cycle. They are one of the few windows the public gets into how regulators grade the largest banks' crisis readiness.
What the release does not do is disclose which specific banks drew which criticisms, whether any plans were rejected outright, or how any of it will change the capital, liquidity or structural requirements those firms face. Those details live inside the supervisory process, not the public docket.
The timing matters. The same week the letters went public, the left-leaning advocacy group Better Markets took aim at separate proposals from the Office of the Comptroller of the Currency and the Federal Deposit Insurance Corporation that it says would loosen the confidentiality rules around confidential supervisory information, or CSI.
Watchdog: 'A Business Asset' for Banks and Their Lobbyists
Better Markets, founded in the wake of the 2008 financial crisis, said in a statement that the OCC and FDIC proposals would let banks circulate examiner findings to third parties — including lobbyists — without prior approval. The group's statement read in part:
"CSI exists so bank examiners can perform their important responsibilities candidly—identifying weak bank management, deficient controls, and emerging risks before they show up in banks' financial statements. It is legally the government's information, and its confidentiality is what allows its examiners to write their judgments plainly. The OCC and the FDIC now propose to turn it into a business asset that banks can circulate to third parties—including their own lobbyists—as they see fit without prior approval."
Better Markets said neither agency identified a public-interest purpose for the proposals and argued they were designed to make bank mergers easier to negotiate. The group further claimed the OCC's own proposal acknowledges that broad disclosure "would chill the OCC's ability to provide meaningful criticism" to banks and that examiners could be "pressured to tailor their supervisory findings" to suit a pending deal.
Better Markets tied the concern directly to the 2023 failures of Silicon Valley Bank and Signature Bank, writing that those institutions collapsed "not because supervisors were too aggressive but because their concerns were not acted on forcefully or quickly enough."
It is not yet known how the Fed's resolution plan letters for the 15 banking organizations intersect with the OCC and FDIC proposals, whether any of the 15 firms received deficiency notices, or when the next round of resolution plan filings is due.
Why This Reaches Beyond Wall Street
For everyday Americans, the stakes are straightforward: resolution plans exist so that the next big bank failure does not end with a taxpayer-funded rescue. The letters published this week are the paper trail of how seriously the largest institutions are preparing for that scenario — and how candidly their examiners are being allowed to say so.
The regulatory pipeline on CSI confidentiality is a separate track, run by the OCC and FDIC rather than the Fed, and it now faces organized opposition from Better Markets and whatever allies the group brings to the comment process. Whether that pushback slows the proposals or gets ignored the way so much financial-sector deregulation does — open for public comment, closed to public influence — is the question nobody in Washington has answered yet.
Our Take
Read the two stories together and the pattern is plain. The Fed posts feedback letters on 15 banks' wind-down plans while the OCC and FDIC float a rule that would let those same banks hand examiner findings to their own lobbyists. That is not transparency for you. That is transparency for the people being examined.
Better Markets is right about the guardrails, even if the group is no friend to this movement: candor from an examiner only exists if the examiner believes the notes stay in government hands. Open that door and the next Silicon Valley Bank gets a supervisor who hedges in writing instead of one who escalates in time.
Conservatives should be the loudest voices against this kind of crony bank deregulation. Big banks are not free-market heroes — they are the first in line for a bailout when their bets go bad, and the resolution plan regime is the only thing standing between their mistakes and your checking account. Gutting examiner confidentiality to grease mergers is a backdoor taxpayer guarantee dressed up as efficiency.
So here is the question for every reader: if these proposals are such good policy, why did the agencies draft them so banks could shop their supervisory findings to lobbyists — instead of putting the letters in front of the public?
