The Federal Reserve and the Federal Deposit Insurance Corporation jointly released on 5 August 2025 the public sections of resolution plans submitted by the eight largest and most complex US banking organisations, together with those of 56 foreign banking organisations. The plans, widely known as living wills, are required under Title I of the Dodd-Frank Wall Street Reform and Consumer Protection Act and are intended to demonstrate that systemically important banks can be wound down in an orderly manner in the event of material financial distress or failure, without requiring a government rescue or causing destabilising disruption to the broader financial system. The publication makes available to market participants a summary account of each institution's resolution strategy and the key assumptions that underpin it.
The documents released publicly represent the non-confidential portions of what are typically much more detailed plans submitted in their entirety to the regulators. The confidential sections contain operationally sensitive information — including counterparty details, intraday liquidity mechanics, and specifics of service continuity arrangements — that is withheld from public disclosure.
THE DODD-FRANK TITLE I FRAMEWORK
Title I of Dodd-Frank, enacted after the 2008 financial crisis, established the resolution planning requirement.
Under the Dodd-Frank regime, the Federal Reserve and the FDIC jointly assess each submitted plan for credibility and feasibility, and may identify deficiencies that the institution must remedy in subsequent submissions. Institutions found to have materially deficient plans face the prospect of additional regulatory requirements — including enhanced capital and liquidity buffers, restrictions on certain business activities, or in the most serious cases divestiture of business lines that impede resolvability. The Federal Reserve oversees bank holding companies, while the FDIC holds the statutory resolution authority for large bank failures.
THE EIGHT-BANK DISCLOSURE
Their resolution plans are submitted on a cycle determined by the regulators, with submission timing reflecting the size and complexity of each institution and the extent of material changes in its business or risk profile since the previous filing.
The Federal Reserve and the FDIC did not indicate in the August 2025 release whether any of the eight plans had been identified as having material shortcomings, a determination that follows a detailed internal review process separate from the public disclosure.