Large Bank Resolution Plan Requirements
Summary
The FDIC is adopting this final rule to require the submission of resolution plans by insured depository institutions (IDIs) with $100 billion or more in total assets and informational filings by IDIs with at least $50 billion but less than $100 billion in total assets. The final rule modifies the current rule requirements regarding the content and timing of full resolution submissions, as well as interim supplements to those submissions provided to the FDIC, in order to support the FDIC's resolution readiness in the event of material distress and failure of these large IDIs. The final rule also enhances how the credibility of full resolution submissions will be assessed, expands expectations regarding engagement and capabilities testing, and explains expectations regarding the FDIC's review, feedback, and enforcement of IDIs' compliance with the rule.
Compliance Requirements
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Submit full resolution plans containing an identified strategy appropriate to the CIDI for its orderly and efficient resolution; Submit informational filings by IDIs with at least $50 billion but less than $100 billion in total assets; Provide an identified strategy for resolution that ensures timely access to insured deposits, maximizes value from the sale or disposition of assets, minimizes any losses realized by creditors of the group A CIDI in resolution, and addresses potential risks of adverse effects on U.S. economic conditions or financial stability; Submit full resolution submissions on a two-year cycle for all CIDIs; Submit periodic interim supplements containing specified resolution submission content items; Meet enhanced credibility standard for full resolution submissions; Participate in engagement and capabilities testing as part of the resolution planning process; Provide valuation analysis to facilitate the FDIC's assessment of least-costly resolution method; Maintain virtual data room capabilities requirement aligned with DFA resolution plan requirements
Deadline: 2024-10-01(October 1, 2024)
Market Impacts
New resolution planning requirements create significant compliance barriers for banks with $50B+ in assets, requiring dedicated resources and specialized expertise; Restricts resolution options by requiring specific identified strategies, potentially limiting flexibility in resolution scenarios and reducing acquirer pool for failed institutions; Creates new market demand for specialized resolution planning consulting services, capabilities testing, and regulatory compliance expertise; Enhanced resolution planning requirements create opportunities for specialized service providers in bridge bank operations and receivership management
Validated Company Impacts
BANK OF AMERICA CORP /DE/
Bank of America is a major insured depository institution with total assets well exceeding $100 billion, placing it directly within the rule's primary scope. As a comprehensive financial institution offering banking, investing, and asset management services, its core operations align perfectly with the FDIC's resolution planning requirements for large financial institutions. The rule focuses on resolution planning for large insured depository institutions, which does not directly address the company's disclosed risks related to goodwill impairment, tangible assets valuation, contingent liabilities, non-GAAP measures, or accounting compliance. There is minimal overlap as the rule's resolution planning requirements could indirectly affect financial reporting and regulatory compliance, but this connection is weak and not explicitly covered by the company's risk factors.
BankUnited, Inc.
BankUnited operates as a bank holding company for an insured depository institution (BankUnited, National Association) providing banking services in the United States, directly falling under the FDIC's jurisdiction for resolution planning requirements. As a banking institution, its core business model aligns perfectly with the rule's focus on insured depository institutions with significant assets, making it highly likely to be subject to these regulatory requirements. The rule focuses on resolution planning and regulatory compliance requirements for large insured depository institutions, while the company's risk profile is dominated by financial and market risks with minimal regulatory compliance exposure. Only one regulatory compliance risk is identified among 28 total risks, indicating very weak alignment with this rule's focus on resolution planning obligations.
CITIZENS FINANCIAL GROUP INC/RI
Citizens Financial Group operates as an insured depository institution with total assets exceeding $50 billion, placing it directly within the scope of this FDIC rule requiring resolution plans and informational filings. The company's core business of deposit-taking and lending activities aligns perfectly with the rule's focus on ensuring orderly resolution of large financial institutions to protect depositors and maintain financial stability. The company's disclosed risk factors show minimal alignment with this FDIC resolution planning rule. While the company identifies regulatory supervision as a risk, this generic compliance concern does not specifically address the complex resolution planning requirements for large depository institutions, and there is no mention of asset size thresholds or resolution strategy execution risks.
COMERICA INC /NEW/
Comerica is a major financial holding company and insured depository institution that operates commercial and retail banking services, placing it directly within the FDIC's regulatory scope for resolution planning requirements. With total assets placing it among the 25 largest U.S. financial institutions, it clearly meets the asset threshold criteria and engages in the exact banking activities targeted by this rule. The rule focuses on financial stability and resolution planning requirements for large depository institutions, while the company's only disclosed risk factor is cybersecurity threats. There is no overlap between the rule's financial regulatory requirements and the company's technology-focused cybersecurity risk profile.
CVB FINANCIAL CORP
CVB Financial Corp operates as a bank holding company with Citizens Business Bank, but the company's total assets are approximately $16.5 billion, which falls well below the $50 billion threshold that triggers any requirements under this FDIC rule. The rule specifically targets insured depository institutions with $50 billion or more in total assets, making it completely inapplicable to CVBF's current scale of operations. The rule directly addresses multiple core risk categories identified by the company, particularly regulatory compliance risks (6 identified), liquidity risks (3 identified), and financial risks (12 identified) through its resolution planning and informational filing requirements. The company's concerns about negative banking industry developments, liquidity risk, and regulatory compliance align strongly with the rule's focus on ensuring orderly resolution during material distress.
FIRST HORIZON CORP
First Horizon Corp operates as a regional bank holding company with over $80 billion in total assets, making it an insured depository institution subject to the FDIC's resolution planning requirements. The company's core banking operations directly align with the rule's jurisdiction, requiring informational filings and periodic interim supplements as an institution with assets between $50-100 billion. The rule's primary impact is on regulatory compliance requirements for large insured depository institutions, which aligns with the company's single regulatory compliance risk factor. However, the company's other major risks (net interest margin compression, deposit competition, bond trading volatility, and mortgage demand decline) are not directly addressed by this resolution planning rule, resulting in minimal overall risk alignment.
HUNTINGTON BANCSHARES INC /MD/
Huntington Bancshares is a major insured depository institution with total assets exceeding $189 billion, placing it well above the $100 billion threshold that triggers full resolution plan requirements. As a comprehensive banking and financial services company operating across commercial, consumer, and wealth management segments, all of its core business activities fall directly under the FDIC's jurisdiction and would be subject to the enhanced resolution planning, credibility assessments, and capabilities testing requirements. The rule focuses specifically on resolution planning requirements for large insured depository institutions, which does not align with any of the company's disclosed risk factors. The company's risks center around credit losses, geopolitical instability, interest rates, loan quality, and goodwill impairment - none of which directly relate to FDIC resolution planning mandates for large banks.
JPMORGAN CHASE & CO
JPMorgan Chase is a major insured depository institution with total assets exceeding $3.9 trillion, well above the $100 billion threshold, and operates as a leading financial services firm offering banking and investment services that fall directly under FDIC jurisdiction. The company's core business model of consumer banking, commercial banking, and financial services aligns perfectly with the rule's requirements for resolution planning, capabilities testing, and data room maintenance. The rule focuses on resolution planning and FDIC compliance for large insured depository institutions, which does not align with the company's disclosed risk factors that primarily concern fair value estimation, accounting standards, and operational estimates. The company's minimal regulatory compliance risks (28 identified) are generic and not specific to banking resolution requirements, indicating no meaningful overlap.
KEYCORP /NEW/
KeyCorp operates as a bank holding company providing banking and financial services, directly falling under the FDIC's jurisdiction as an insured depository institution. The company's core business model aligns perfectly with the rule's requirements for resolution planning and informational filings based on asset thresholds. The rule focuses on resolution planning and financial stability requirements for large depository institutions, while the company's risk profile centers on cybersecurity threats, third-party vulnerabilities, and information security program effectiveness. There is minimal overlap as the company's regulatory compliance risk is generic and not specifically tied to resolution planning or asset size thresholds.
M&T BANK CORP
M&T Bank Corp is an insured depository institution operating as a commercial and retail bank, directly falling under the FDIC's jurisdiction for resolution planning requirements. With total assets exceeding the $100 billion threshold, the company would be required to submit full resolution plans and comply with all enhanced credibility standards, engagement testing, and data room requirements specified in the rule. The rule specifically targets resolution planning for large insured depository institutions, which does not align with the company's general regulatory compliance risk factor. The company's identified regulatory risk is broad and non-specific, while this rule applies only to banking institutions meeting specific asset thresholds, making the alignment minimal.
REGIONS FINANCIAL CORP
Regions Financial Corp is an insured depository institution with total assets of $152.4B ($102.3B commercial + $11.4B investor real estate + $78.6B consumer bank + $7.7B wealth management), placing it well above the $100B threshold requiring full resolution plan submissions. The company operates as a traditional banking institution providing commercial, retail, and mortgage banking services, directly falling under the FDIC's jurisdiction for resolution planning requirements. The rule focuses specifically on resolution planning and regulatory compliance for large insured depository institutions, which does not directly address any of the company's disclosed risk factors. While the company mentions legal/regulatory compliance risks generally, there is no specific alignment with resolution planning requirements or the operational impacts described in the rule.
SYNOVUS FINANCIAL CORP
Synovus Financial Corp is an insured depository institution with approximately $60 billion in total assets, placing it squarely within the $50-100 billion asset range that requires informational filings under this rule. As a regional bank holding company operating primarily in the Southeast US, its core business of commercial and consumer banking directly falls under FDIC jurisdiction and resolution planning requirements. The rule's focus on resolution planning for large insured depository institutions does not directly address the company's disclosed risks of funding cost/availability changes or client confidence erosion in the banking system. While the rule aims to enhance financial stability, it creates compliance burdens rather than mitigating the specific funding and confidence risks the company has identified.
WESTERN ALLIANCE BANCORPORATION
Western Alliance Bancorporation operates as an insured depository institution in the banking sector with $65.7B in deposits, placing it squarely within the $50-100B asset range that requires informational filings under this FDIC rule. The company's core business of loans and deposits directly aligns with the resolution planning requirements for large financial institutions. The rule focuses on resolution planning requirements for large insured depository institutions, which does not directly address the company's primary risk factors related to CRE market exposure, charge-offs, or foreclosure issues. The only potential alignment is the mention of FDIC special assessments, but this rule concerns resolution planning rather than assessment funding mechanisms.
COLUMBIA BANKING SYSTEM, INC.
Columbia Banking System operates as an insured depository institution with total assets exceeding $50 billion, placing it directly within the scope of this FDIC rule requiring resolution plans and informational filings. The company's core banking operations and financial services activities align perfectly with the rule's jurisdiction over large insured depository institutions. The rule focuses on resolution planning and regulatory compliance for large insured depository institutions, while the company's risk profile shows only one regulatory compliance risk among its top concerns, with primary emphasis on operational, market, and cybersecurity risks that are not directly addressed by this specific FDIC resolution rule.
FIRST CITIZENS BANCSHARES INC /DE/
First Citizens BancShares is an insured depository institution with total assets exceeding $100 billion, operating directly within the banking sector targeted by this FDIC rule. The company's business model involves comprehensive capital adequacy processes, risk-based calculations, and stress testing, which directly align with the resolution planning requirements for orderly resolution strategies and enhanced credibility standards. The rule focuses on resolution planning requirements for large insured depository institutions, which does not align with the company's primary disclosed risk of cybersecurity threats. There is minimal overlap as the rule addresses financial stability and regulatory compliance risks for banking institutions, while the company's risk profile centers on technology security concerns.
FLAGSTAR FINANCIAL, INC.
Flagstar Financial operates as a bank holding company with insured depository institution operations through Flagstar Bank N.A., which would clearly fall under the FDIC's jurisdiction for resolution planning requirements if it meets the asset threshold. However, the provided business operations data does not include any information about the company's total assets, which is the critical determining factor for applicability of this rule requiring $50B+ in assets. The rule directly addresses the company's identified regulatory compliance risks by imposing new resolution planning requirements that would increase compliance costs and operational restrictions. It also aligns with operational risk concerns through requirements for enhanced capabilities testing and virtual data room maintenance that could mitigate potential failures in processes or systems.
NORTHERN TRUST CORP
Northern Trust Corp is a major financial institution and insured depository institution with over $150 billion in total assets, placing it squarely within the $100B+ asset threshold that requires full resolution plan submissions. As a global custody bank and asset servicing provider, its core business operations fall directly under FDIC jurisdiction and would be significantly affected by all resolution planning requirements including strategy development, capabilities testing, and virtual data room maintenance. The federal rule specifically targets insured depository institutions with $50 billion or more in total assets, focusing on resolution planning requirements for large banks. The company operates in the technology sector with no banking operations, depository services, or financial institution characteristics, making this rule completely irrelevant to its risk profile and business model.
PNC FINANCIAL SERVICES GROUP, INC.
PNC Financial Services Group is a major insured depository institution with over $500 billion in total assets, placing it well above the $100 billion threshold that triggers full resolution plan requirements. As one of the largest U.S. banking institutions, PNC's core business operations directly fall under the FDIC's jurisdiction and would be significantly affected by all resolution planning, submission, testing, and data maintenance requirements. The rule directly addresses the company's top regulatory change and compliance risks by imposing new resolution planning requirements that could result in penalties and operational restrictions. The enhanced resolution planning and testing requirements also align with operational risk management concerns, as failure could lead to significant financial losses and reputational damage.
WESBANCO INC
Wesbanco is a financial institution that manages liquidity risk through liquid assets, borrowing capacity, and stable deposits, but the rule specifically targets insured depository institutions with $50B+ in assets, which is not confirmed here. Without evidence of meeting the asset threshold or being an insured depository institution, there is no operational alignment with the rule's requirements. The company has identified regulatory compliance risks as a significant concern (7 risks identified), which directly aligns with this rule's requirement for enhanced resolution planning and compliance obligations. The rule's focus on financial stability and regulatory actions matches the company's disclosed regulatory and financial risk categories.
ZIONS BANCORPORATION, NATIONAL ASSOCIATION /UT/
Zions Bancorporation operates as an insured depository institution providing banking services primarily in the Western United States, directly falling under the FDIC's jurisdiction for resolution planning requirements. With total assets exceeding the $50 billion threshold, the company would be required to submit resolution plans and informational filings as specified in the rule. The rule focuses on resolution planning and financial stability requirements for large depository institutions, which does not directly address any of the company's identified risk factors. The company's risks are primarily credit quality, cybersecurity, operational disruptions, talent retention, and counterparty concentration - none of which are specifically mitigated by resolution planning mandates.