Federal banking agencies on Tuesday published resolution plan feedback letters for 15 banking organizations, releasing the behind-the-scenes correspondence that tells large banks whether their plans for an orderly shutdown in a crisis pass muster — and where regulators want more work done.
The disclosure landed the same day Federal Reserve Vice Chair for Supervision Michelle Bowman used a speech in St. Louis to take aim at the regulatory machinery that governs how community banks grow, merge and compete.
Resolution plans, often called living wills, spell out how a financial firm would be unwound under bankruptcy without a taxpayer bailout or a shock to the wider financial system. Regulators review the plans and issue feedback letters identifying shortcomings, pressing for revisions, or flagging that a plan is not credible. The letters published Tuesday cover 15 organizations, though the specifics of each bank's deficiencies and required fixes were not detailed in the public headline summary of the release.
Bowman Takes On the Merger Machine
Speaking at the Community Banking Research Conference in St. Louis, Bowman said the Fed has spent the past two years refocusing supervision on risks that could actually affect a firm's financial condition, updating the community bank leverage ratio with other banking agencies, and eliminating the Novel Activities Supervision Program to give community banks room to innovate. That's per reporting from PYMNTS, which covered the speech Tuesday.
One area where Bowman said the work is unfinished: mergers and acquisitions.
"This analysis is antiquated and harmful to community banks that may face greater difficulties in merging, even when doing so may actually create a stronger and more competitive banking environment," Bowman said, according to PYMNTS.
Bowman said the Fed's competitive analysis in bank mergers disproportionately affects rural banks operating in small and underserved markets and understates the competition those banks actually face. Read that plainly: the government's math treats a small-town bank as a monopolist in a market where it may be the only option left standing, and then blocks the deal that could have kept it alive.
She pointed to de novo bank formation as another front where federal and state agencies could do more — clarifying approval standards like capital requirements, committing to specific and reasonable processing timelines, and issuing conditional approvals where appropriate.
A third unfinished item is the call report. Bowman noted the Federal Financial Institutions Examination Council issued a request for information on call report streamlining in December 2025, seeking public comment on the burden the Consolidated Reports of Condition and Income places on banks and asking stakeholders to identify options for reducing it.
ABA Pushes for Coordination
The American Bankers Association raised its own concerns about the rewrite of disclosure rules now underway, telling regulators they need to coordinate with each other on rulemaking, according to ABA Banking Journal. The trade group's message: banks are being handed overlapping and sometimes conflicting demands from multiple agencies at once.
Put the two stories side by side and a pattern shows up. Regulators are publishing the paperwork that governs how the largest institutions would be dismantled in a crisis, while the official in charge of supervision says the rules governing whether small banks can combine, open or even file their quarterly reports are due for a rewrite.
What This Means for Your Town
For everyday Americans, resolution plan letters read like inside baseball — until the next crisis, when the question of who gets bailed out and who gets wound down becomes very real, very fast. The merger analysis Bowman described is nearer to home. When a rural bank can't merge, it doesn't usually get stronger. It gets smaller, older and more isolated, and the customers in those underserved markets lose branches, lenders and options.
Bowman is expected to keep pressing the de novo and call report issues through the Fed and the FFIEC process. The 15 feedback letters are now public, and the banks named in them will be working through whatever revisions regulators demanded. Whether the disclosure produces real accountability — or just another stack of filings nobody reads until it's too late — is the part the agencies haven't answered yet.
Our Take
Here's the thing about the administrative state: it never announces itself. It doesn't show up at your door. It shows up as a merger application that dies in a review queue, a de novo charter that never gets approved, a call report that eats a community bank president's entire weekend. Bowman just named three of those quiet killers out loud, and she's right on all three.
The competitive analysis blocking rural bank mergers is the worst of them. It pretends a bank in a small market is a monopolist when it may be the last lender standing between a farmer and a city bank that doesn't know his name. Blocking the merger doesn't protect competition — it protects the status quo, and the status quo in rural America is fewer banks, not more.
The 15 resolution letters dropped the same day, and the timing is a reminder of what the agencies actually spend their time on. Living wills for giants, while the community banks that fund Main Street wait on approval standards, timelines and a call report that should have been streamlined years ago. The Fed didn't have to be pushed into publishing that feedback — but the public shouldn't have to dig through a Tuesday news dump to find out whether the banks too big to fail are actually prepared to fail.
Watch the FFIEC's call report process and the next round of merger rulings. If Bowman's words turn into revised standards and real timelines, community banks get a fighting chance. If they stay words, nothing changes — and patriots in small towns keep watching their last bank get squeezed by a formula written for markets that don't exist anymore.
