The simple version

After the 2008 financial crisis, Congress passed the Dodd-Frank Act, which required the largest U.S. bank holding companies and certain non-bank financial firms to write detailed plans for how they would be wound down if they ran into severe financial trouble. These plans are formally called resolution plans. They are widely called living wills, on the analogy of a person writing instructions for their estate. The Federal Reserve and the Federal Deposit Insurance Corporation jointly review the plans, send the banks back feedback letters describing any shortcomings or deficiencies, and require revisions. Banks update and resubmit their plans on a recurring schedule.

On May 22, 2026, the FDIC and the Federal Reserve published feedback letters on the resolution plans that eight of the largest and most complex U.S. domestic banking organizations and 56 foreign banking organizations submitted in July 2025. The headline finding is short. The agencies did not identify any shortcomings or deficiencies in any of the plans. Each derivatives-related weakness that the agencies flagged in the 2023 plans from Bank of America, Goldman Sachs, JPMorgan Chase, and Citigroup has been satisfactorily addressed.

The numbers

• Date of release: May 22, 2026. (Federal Reserve and FDIC joint press release: https://www.federalreserve.gov/newsevents/pressreleases/bcreg20260522a.htm)
• Number of largest, most complex U.S. domestic banking organizations covered in this review: 8. (FDIC press release, May 22, 2026: https://www.fdic.gov/news/press-releases/2026/agencies-publish-resolution-plan-feedback-letters-certain-domestic-and)
• Number of foreign banking organizations covered: 56. (FDIC press release, May 22, 2026)
• Resolution plan submission date: July 2025. (FDIC press release, May 22, 2026)
• Number of shortcomings or deficiencies the agencies identified in the 2025 plans: 0. (Federal Reserve and FDIC joint press release, May 22, 2026)
• Banks whose 2023 derivatives-related weaknesses are now satisfactorily addressed: Bank of America, Goldman Sachs, JPMorgan Chase, and Citigroup. (FDIC press release, May 22, 2026)
• Legal basis for the resolution plan requirement: Title I, Section 165(d) of the Dodd-Frank Act of 2010. (FDIC Resolution Authority page: https://www.fdic.gov/resources/resolutions/resolution-authority/)

How the resolution plan process actually works

A resolution plan is a long, technical document. For the largest U.S. banks, it runs into the thousands of pages, with a public summary and a confidential full version. The plan has to describe, in operational detail, how the bank would be unwound if it failed: which legal entities would be put into bankruptcy, how the operating subsidiaries (the parts of the bank that hold customer deposits and run payments) would be kept open or transferred to another firm, how derivatives contracts would be terminated, how foreign operations would be coordinated with foreign regulators, and how all of this would happen without forcing the U.S. government to step in.

The Federal Reserve and the FDIC read each plan and identify two categories of problem. A shortcoming is something the agencies want addressed in the next plan. A deficiency is more serious: a problem so significant that it raises questions about whether the bank could actually be resolved as described, and if not corrected, can lead to formal enforcement action. When the agencies find no shortcomings and no deficiencies in a round of plans, as they did on May 22, 2026, it is the regulatory equivalent of passing every section of the test on the first try.

The agencies separate this Title I process from the Title II process. Title I, which is what the May 22 letters are about, is the planning ahead process: banks have to write down how they would fail in an orderly way, under ordinary bankruptcy law. Title II is the backstop, the Orderly Liquidation Authority that lets the FDIC actually run a resolution if bankruptcy will not work. The two are designed together. The Title I plans exist so that, if a bank does get into severe distress, regulators and the bank already share a playbook before the panic starts.

The Real Cost lens on what living wills mean for an FDIC-insured deposit

A household reader does not interact with a resolution plan directly. The relevant question is what it means for your money to be in a bank that has just been graded on its living will. Here is the practical translation.

• FDIC deposit insurance covers up to $250,000 per depositor, per insured bank, per ownership category. For a checking, savings, or money market deposit account, that is the first line of protection if a bank fails, and it operates regardless of how the bank's resolution plan was graded.
• For balances above the $250,000 limit, or for non-deposit products like brokerage accounts or money market mutual funds, the resolution plan is part of what reduces the probability of disorderly failure. A clean resolution plan grade does not change deposit insurance. It does mean the regulators believe the bank can be wound down without triggering a broader panic.
• For a household with a mortgage at one of the eight largest U.S. banks, a clean resolution plan grade means the regulators believe the bank's failure could be handled with minimal disruption to the servicing of that mortgage. The loan itself would survive a bank failure (it is an asset on the bank's books that another institution would take over), but operational continuity matters when you are still paying it.
• For a household with a business banking relationship at one of these banks, the same logic applies. Operational continuity through a resolution event is what the plans are designed to preserve. The grade is the regulators' read on whether that preservation is credible.

The Real Cost lens point is not that you should move your account around based on a resolution plan grade. The real cost was already paid in 2008, in the form of public bailouts and the long recession that followed. The resolution plan process exists to make a future round of those costs less likely. A clean grade is one data point that the system regulators built after 2008 is working as designed, in this particular cycle, for these particular banks.

What this means

There are two ways to read a clean round of resolution plan feedback. The optimistic read is that the post-2008 architecture is mature: the largest banks now have well-rehearsed wind-down plans, the agencies have a stable framework for evaluating them, and serial revisions have gradually closed the operational gaps that the early plans had. The skeptical read is that no plan has ever actually been tested by a real failure of a global systemically important bank, and the 2023 failures of Silicon Valley Bank, Signature Bank, and First Republic, none of which were in the Title I category covered by these feedback letters, showed how quickly a bank failure can move from quiet to systemic.

Both reads can be true at the same time. The resolution plan process is a planning exercise, not a stress test. It is one part of a larger regulatory regime that also includes capital requirements, liquidity requirements, the annual stress tests, and the agencies' supervisory work. A clean grade in one round is a sign the planning piece is working. It is not a guarantee about the next crisis, which will probably look different from the one the plans were written for.

What this is NOT

This article is not a prediction about whether any of these banks will fail. It is not a recommendation to deposit money with, withdraw money from, buy stock in, or short any of the named banks. It is not a comprehensive read on bank safety, which depends on capital, liquidity, supervision, and stress tests in addition to resolution planning. It is not legal or investment advice. Most useful between ages 25 and 70, for anyone who banks at a large U.S. financial institution and has wondered what 'too big to fail' actually means in 2026, sixteen years after the Dodd-Frank framework took effect.

Sources

• Federal Reserve Board, press release: Agencies publish resolution plan feedback letters for certain domestic and foreign banking organizations, May 22, 2026. https://www.federalreserve.gov/newsevents/pressreleases/bcreg20260522a.htm
• FDIC, press release: Agencies Publish Resolution Plan Feedback Letters for Certain Domestic and Foreign Banking Organizations, May 22, 2026. https://www.fdic.gov/news/press-releases/2026/agencies-publish-resolution-plan-feedback-letters-certain-domestic-and
• FDIC, Resolution Authority page (Title I and Title II frameworks). https://www.fdic.gov/resources/resolutions/resolution-authority/
• Federal Reserve, Resolution Plans (Title I living wills) supervision page. https://www.federalreserve.gov/supervisionreg/resolution-plans.htm