United States · Official update
Agencies publish resolution plan feedback letters for 15 banking organizations
The Federal Deposit Insurance Corporation and the Federal Reserve Board today published feedback letters for resolution plans submitted in October 2025. The agencies did not identify any shortcomings or deficiencies in these resolution plan submissions.
Resolution plans, also known as living wills, describe a banking organization's strategy for orderly resolution in the event of material financial distress or failure. The agencies conducted a joint review of the 2025 resolution plan submissions from 15 banking organizations with over $250 billion in assets.
In addition, the agencies determined that the shortcoming previously identified in the 2021 BNP Paribas resolution plan has been satisfactorily addressed.
American Express Company 2025 Resolution Plan Feedback Letter (PDF)
Barclays PLC 2025 Resolution Plan Feedback Letter (PDF)
BNP Paribas 2025 Resolution Plan Feedback Letter (PDF)
Deutsche Bank AG 2025 Resolution Plan Feedback Letter (PDF)
UBS Group AG 2025 Resolution Plan Feedback Letter (PDF)
Template Letter to Category II and III Firms with Resolution Plans Due in October 2025 (PDF)
PDF summaries & supporting documents
Inside the document
What the PDF says
2025 Plan Feedback Letter for American Express Company
AI-generated summary · 4-page source document
The feedback letter emphasizes that American Express Company made significant improvements in their 2025 resolution plan. However, the agencies advised revising the proposed 'Coordinated Sale Strategy' due to feasibility concerns. A successful resolution strategy is essential for financial stability, requiring careful planning and execution.
Key points
Resolution Plan Review
The Agencies did not identify any shortcomings or deficiencies in the Covered Company’s 2025 Plan.
Source: PDF page 1Improvement Over Previous Submissions
the Agencies noted meaningful improvements over the Covered Company’s prior resolution plan submissions, including further development of capabilities
Source: PDF page 1Coordinated Sale Strategy Concerns
The Agencies have concluded that there is significant uncertainty regarding the feasibility of the process outlined in the 2025 Plan
Source: PDF page 3Future Planning
the Resolution Plan Rule requires the Covered Company to submit a targeted resolution plan on or before July 1, 2028.
Source: PDF page 3
What this means
Resolution plans, also known as living wills, are essential for large banks to ensure they can be managed effectively in the event of financial distress. The review emphasizes the importance of developing solid strategies to protect financial stability while addressing potential operational complexities during a crisis.
Key term: Resolution Plan
A resolution plan outlines a company's strategy for rapid and orderly resolution in the event of material financial distress or failure.
AI-generated from the source PDF. Verify important details in the original. Generated October 27, 2026. Read source PDF
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Source & attribution
Source: Federal Reserve. Text reproduced in DailyMIQ’s reading format. Images, charts, navigation, and media contact details are omitted. The source does not endorse DailyMIQ. The original is available free of charge.
View original publicationReferences & supporting documents
- American Express Company 2025 Resolution Plan Feedback Letter (PDF)
- Barclays PLC 2025 Resolution Plan Feedback Letter (PDF)
- BNP Paribas 2025 Resolution Plan Feedback Letter (PDF)
- Deutsche Bank AG 2025 Resolution Plan Feedback Letter (PDF)
- UBS Group AG 2025 Resolution Plan Feedback Letter (PDF)
- Template Letter to Category II and III Firms with Resolution Plans Due in October 2025 (PDF)