Fed and FDIC find no shortcomings in 15 banks' living wills; Reg O comment period extended
Victoria Shinder2 min readThe Federal Reserve Board and the Federal Deposit Insurance Corporation published feedback letters on 29 September for the resolution plans that 15 banking organisations with more than $250 billion in assets submitted in October 2025. The agencies said they did not identify any shortcomings or deficiencies in those submissions.
What a living will is. A resolution plan describes how a banking organisation would be wound down in an orderly way if it faced material financial distress or failed. The 15 plans were reviewed jointly by the two agencies. The release links a feedback letter to each firm, including American Express, and a template letter to the Category II and III firms whose plans were due in October 2025.
An old finding closed. The agencies also determined that a shortcoming they had identified in BNP Paribas's 2021 resolution plan has been satisfactorily addressed.
Insider lending: more time to comment. On 2 October the Fed said it would extend to 4 November the comment period on its proposal to modernise Regulation O, the rule that governs credit a bank extends to its insiders: executives, directors and principal shareholders who could influence its lending decisions. Comments had been due by 5 October; the Board said the extension gives interested parties more time to analyse the issues and prepare their comments.
What the releases do not say. The living-will release gives no detail on the agencies' assessment beyond the absence of findings, and the Regulation O release does not restate the content of the proposal.
What it means
A clean round of living-will reviews means none of the 15 firms faces a requirement to fix and resubmit, which is the step that follows a deficiency finding. For banks and their insiders, the Regulation O extension is the practical news: the window to shape the modernised insider-lending rules is now a month longer.