The Federal Deposit Insurance Corporation published a Financial Institution Letter updating insured depository institution resolution planning expectations for covered insured depository institutions as it develops proposed amendments to the IDI Rule. The update previews 2026 rulemaking priorities, revises certain 2026 submission expectations and sets out planned capabilities testing related to the FDIC’s virtual data room. Planned amendments for FDIC Board consideration in 2026 are expected, at a minimum, to codify the content requirement exemptions and frequently asked questions associated with the modified approach released in April 2025, alongside further changes based on the FDIC’s review of 2025 submissions to prioritize information needed for rapid, low-cost resolution under the Federal Deposit Insurance Act and remove lower-value requirements. The FDIC is also evaluating overlap between the Title I Rule (bank holding company resolution plans) and the IDI Rule. For 2026 submissions, covered IDI subsidiaries of U.S. global systemically important banks scheduled to file full submissions by July 1, 2026 will instead submit content equivalent to an interim supplement by that date; remaining Group A CIDIs will file as scheduled subject to existing waivers and additional waivers for valuation content; Group B CIDIs due April 1, 2026 or July 1, 2026 will file as scheduled subject to existing waivers; and Group B CIDIs due October 1, 2026, plus any IDIs that become CIDIs before a final rule is issued, will not be required to file until a final rule is issued (including interim supplements otherwise due October 1, 2026). The stated applicability is to FDIC-insured depository institutions with USD 50 billion or more in total assets. Capabilities testing in 2026 will assess CIDIs’ ability to populate certain information into the FDIC’s virtual data room, with testing expected to begin in early 2026 for CIDIs that filed full submissions in 2025 and, for 2026 full filers, in the months following the relevant submission deadline. Advance notification and instructions are expected about 30 days before testing begins, and the FDIC expects to conduct capabilities testing for U.S. GSIB CIDI subsidiaries through the Title I planning process.
Federal Deposit Insurance Corporation 2025-12-31
Federal Deposit Insurance Corporation updates large bank IDI resolution planning with 2026 filing adjustments and planned rule amendments
The Federal Deposit Insurance Corporation (FDIC) updated resolution planning expectations for covered insured depository institutions (CIDIs) as it prepares amendments to the IDI Rule, highlighting 2026 rulemaking priorities and capabilities testing for its virtual data room. Amendments will codify content requirement exemptions and address overlaps with the Title I Rule, focusing on rapid, low-cost resolution under the Federal Deposit Insurance Act. CIDIs with USD 50 billion or more in assets will have adjusted submission requirements for 2026, with capabilities testing beginning early that year.